The U.S. Food and Drug Administration (FDA) requires Nutrition Facts labeling on food products sold in the United States, whether they are produced domestically or outside of the United States. Coffee, tea, and spices may be exempt from FDA nutrition labeling requirements if they contain “insignificant” (by FDA’s definition of the term) amounts of all nutrients required to be included in the “Nutrition Facts” panel (fda.gov). Limitations to the exemption exist, and it is important for companies to understand when their product will qualify. Products that are required to declare nutrition labeling, but do not, may be detained for misbranding and refused entry into the United States.
The exemption from nutrition labeling applies to the finished food product, as packaged. If foods with insignificant amounts of nutrients are combined, the resulting product remains exempt. For example, plain coffee and cinnamon both contain insignificant nutrient amounts; therefore, if combined into a single product, the result is still exempt from nutrition labeling. Once an ingredient with nutrients is added to the product, it no longer has insignificant amounts of nutrients and a Nutrition Facts label is required. Common examples include: chai latte mixes, sugar/sweetener, and candied fruit peel.
Claims and Other Nutrition Information
If any of the following types of claims are made, a Nutrition Facts Label is required:
- A nutrient content claim (“low-fat”, “healthy” or “high in fiber”)
- A health claim (“Diets low in sodium may reduce the risk of high blood pressure, a disease associated with many factors”)
- A structure/function claim (“calcium builds strong bones”)
FDA regulations also state that the exemption does not apply if any nutrition information is present on the label.
In the example above, the tea on the left has no claims or added nutrients and therefore does not require a Nutrients Facts label. The tea on the right, however, does require a Nutrition Facts label because it provides the amount of antioxidants (catechins) present in the product, which could be construed as “nutrition information” by FDA.
If your product is exempt for Nutrition Facts labeling, voluntary information may still be provided. Some consumers seek more information on how the product was manufactured and find value in transparency.
Registrar Corp’s Regulatory Specialists can help you determine if your products require a Nutrition Facts label and keep your company in compliance with FDA regulations. Contact us by phone at +1-757-224-0177 or chat with a Regulatory Advisor 24 hours a day at www.registrarcorp.com/livehelp.