How to Read Food Labels - Introduction to Food Label Claims

What is a food label?

What government agencies regulate food labeling?

Food and Drug Administration (FDA)
US Department of Agriculture (USDA)

FDA gets its authority to regulate food labels from the Food, Drug, and Cosmetic Act (FDCA); Nutrition Labeling and Education Act (NLEA); Fair Packaging and Labeling Act (FPLA); Public Health Service Act (PHS); and Food Allergen Labeling and Consumer Protection Act (FALCPA). FDA has also developed many regulations to implement these laws. While FDA has a number of requirements for information that must be included, it does not preapprove food product labels prior to use.

FDA has a few general requirements for any labels it regulates. All food labels must include the following:

Name of the food
Net quantity of contents
Name and location of the business
List of ingredients if the food is comprised of more than one ingredient
Nutrition Fact Label (for packaged products sold at retail)
Allergen disclosure information for products which contain one or more of the eight major food allergens (e.g., processed in a facility with nuts)

Find additional FDA guidance on various labeling requirements here. These guides cover topics from how to properly label sugar to menu and vending machine labeling requirements.

The name of a food product may be defined by a “statement of identity.” A statement of identity is either the name established by law, or the usual name of the food if there is no legal definition.

FDA enforces food labeling by conducting inspections of production facilities. When FDA finds a food label that qualifies as a “violation of regulatory significance,” it will issue the manufacturer a warning letter requesting a labeling correction. In less severe cases, FDA will issue an advisory letter. In the most severe cases, FDA has the authority to issue a mandatory recall, though this is rare. Some examples of labeling violations can be found here. You can read more about FDA enforcement here.

USDA gets its authority to regulate food labels from the Federal Meat Inspection Act (FMIA) and the Poultry Products Inspection Act (PPIA), which prohibit misbranding of meat and poultry products.

Like FDA, USDA requires several components on the food labels it regulates, including:

Name of the food
Inspection legend and establishment number (a symbol showing that a carcass or parts of carcasses were inspected in an official establishment in accordance with all federal regulations)
Handling statement (e.g., “Keep Frozen”)
Safe handling instructions (required if the meat or poultry component of a product is raw or partially cooked)
- Statement must read: “This product was prepared from inspected and passed meat and or poultry. Some food products may contain bacteria that could cause illness if the product is mishandled or cooked improperly. For your protection, follow these safe handling instructions.” May have additional instructions afterward.
Net weight statement
Ingredients statement (must list ingredients when product is made from 2 or more ingredients, listed in order of weight of ingredients)
Address line (trade name or place of business of the manufacturer, packer, or distributor)
Nutrition facts

Like FDA-regulated products, the name of the food that appears on the label is the “statement of identity.” A statement of identity is either the name established by law, or the usual name of the food if there is no legal definition. See the USDA Food Standards and Labeling Policy Book for more information. You can find an overview of USDA label requirements here.

Unlike labels for products regulated by FDA, labels on meat and poultry products must be preapproved by USDA before entering the market. USDA also performs inspections of establishments to ensure manufacturers are in compliance with regulations. Additionally, individuals and industry members can file complaints about labeling violations, such as labels not in compliance with USDA Organic regulations. When labels are found to violate USDA regulations, USDA may issue a warning letter or retain, condemn, or recall the product so as to ensure the misbranded product does not enter the food system. You can read more about USDA compliance and enforcement here.

I. Regulated Voluntary Label Claims

Food labels include all sorts of claims about the food’s content, nutrition, the place the food comes from, and much more. As discussed above, some of those claims are required to be on the labels, like nutrition facts. Other claims are not required, but food producers can choose to include them because it makes their product more valuable or appealing to consumers. These voluntary label claims are very common and they are the claims consumers often use to make important purchasing decisions. Some of these claims are defined by law and others are not. For those voluntary label claims that are not specifically defined, the law still prohibits them from being false and misleading to consumers. Both USDA and FDA have defined certain voluntary label claims, examples of which are provided below.

Nutrient Content Claims

According to FDA, a “Nutrient Content Claim is a claim that characterizes the level of a nutrient in the food.” So, any claims about the nutrients in a food (except for the “Nutrition Facts” panel) are considered nutrient content claims because they describe the amount of a nutrient in the food rather than just stating the specific quantity (e.g., 3 grams of sugar). Nutrient content claims can make statements about the presence of a nutrient, the relative levels of a nutrient, and the absence of a nutrient. There are several kinds of nutrient content claims; the information below explains some of the most common. For more information on nutrient content claims, visit this summary of Nutrient Content Claims.

a) Relative claims: Relative nutrient claims, like “low,” “free,” “high,” “light,” and “reduced,” are used to differentiate a product from similar products based on its nutrient content. “Free” and “low” claims, like “fat-free” or “low sodium,” imply that the marketed food has a legally defined amount of fat, calories, cholesterol, sodium, or sugar per serving. “Reduced,” “less,” “light,” and “high” are considered relative terms and are defined in relation to the regular version of the product. Food labels using relative claims must state which food is being used for comparison and the specific measured difference between the two foods, such as “50 percent less fat than (reference food).”

For labels that compare a food to the nutrient levels in a different food (including claims like “less,” “fewer,” and “more”), the food must actually meet those label claims when compared to a reference food in the same category. For example, comparing potato chips to pretzels, or comparing mozzarella cheese to cheddar cheese.

For “light,” “reduced,” “added,” “extra,” “plus,” “fortified,” and “enriched” claims, the marketed food must be compared to the same food. So, reduced sodium potato chips would need to be specifically made to have less sodium than similar potato chips; light cream cheese would be compared to regular cream cheese.

Note that claims about fat and cholesterol are more specifically regulated. “Reduced fat” foods must have at least 25% less fat than reference foods, and “low fat” foods have 3g of fat or less per serving. “Fat-free” and “skim” products have less than 0.5g of fat per serving. “Cholesterol-free” foods have less than 2 mg of cholesterol per serving. Foods that claim “low cholesterol” or similar claims have less than 20 mg of cholesterol per serving.

For more information on legal requirements about relative claims, see FDA’s regulations.

High/Good Source of/More: FDA regulates claims about whether a food is a “good source of” a particular nutrient or vitamin. Generally, labels may make “good source of” claims if the food contains between 10 and 19 percent of the reference daily intake or daily reference value ordinarily consumed. To use the term “more,” the food must contain at least 10 percent more of the nutrient than a reference food of the same serving amount. The term “high” can be used if the food contains at least 20 percent more of the nutrient than a reference food of the same serving amount. See FDA regulations for more information.

b) Implied nutrient content claim: Implied nutrient content claims are claims that describe a food or ingredient in a way that suggest that a specific nutrient is present or absent in amounts (like “high in oat bran”) or suggest the food is useful in maintaining some healthy dietary practice because a certain ingredient is present or absent. An implied nutrient content claim is not the same as simply saying that some ingredient is or is not present. The claim must lead the consumer to connect the nutrient to some additional dietary assumption about the presence or absence of the nutrient or ingredient. FDA only allows some nutrient content claims on labels. These claims are listed in FDA regulations. Outside of these pre-established claims, an implied nutrient content claim cannot appear on a food label.

c) Healthy, healthful, healthiness: FDA allows the use of the term “healthy” (or related terms such as “healthful,” “healthily,” “healthiness,” etc.) as an implied nutrient content claim on food labels when it is useful for creating a diet consistent with dietary recommendations. The nutrient conditions necessary for a “healthy” diet include specific criteria for nutrients to limit in a diet, such as total fat, saturated fat, cholesterol, and sodium. The nutrient criteria to use this claim varies for different food categories, and are different for raw fruits and vegetables than for frozen or canned fruits and vegetables, enriched cereal products, and seafood or meat products. For more information on this term, see FDA’s Guidance for Industry: Use of the Term “Healthy” in the Labeling of Human Food Products.

Structure/Function claims

USDA Grades

USDA Organic

This term means that a product has been produced according to the standards in the Organic Foods Production Act (OFPA) and certified by USDA’s National Organic Program or a state’s organic program which meets the same minimum standards as USDA’s program. A label may only use the “USDA Organic” seal if the food is actually certified organic. However, a package may still note which ingredients, or percent of ingredients, are USDA organic. Some producers, such as organic farmers who sell less than $5,000 in food per year, may also market their products as organic without certification.

Organic products are grown and processed according to federal standards on soil quality, pest and weed control, and use of chemical fertilizers, among other areas. According to USDA, “[o]rganic producers rely on natural substances and physical, mechanical, or biologically based farming methods to the fullest extent possible.” Additionally, the use of genetically modified organisms (GMOs) is “prohibited in organic production or handling.”

The amount of organic ingredients in a food matters for labeling. A “100% organic” product may only have ingredients that are organic. A food that has at least 95 percent organic ingredients may have the term “organic” on its label, if the organic ingredients are specifically noted somewhere on the package. If the product has at least 70 percent organic ingredients, the package may use the term “organic” to list the specific qualifying ingredients, but may not use the USDA Organic seal. Foods with organic ingredients, but which are less than 70 percent organic, may only use the term “organic” in the ingredient list or the percentage of organic ingredients.

USDA regulations require that the labels of certain agricultural products include language identifying the name of the certifying agent with language like “Certified organic by ____” which can enable consumers and others to know who certified the product as organic.

For more information on organic ingredient labeling, see the USDA Organic Labeling Standards website.

USDA Process Verified

II. Undefined Voluntary Label Claims

As you will see by exploring Labels Unwrapped, many of the claims we see first on food packages are undefined voluntary claims. As stated above, voluntary label claims are used to market the product and make it stand out, like “sustainable” or “superfood.” Producers have a fair amount of discretion to choose what terms they use, and what those terms mean. However, they must ensure these claims are not false or misleading. A claim can be false and misleading not only based on what the label says or what imagery is included, but also what the label fails to say or even how the claims appear.

Third-Party Certifications

Frequently Asked Questions

How accurate are food label claims? Which ones can I trust, and how do I know I can trust them?
Does a food label have to be approved before it is used?
What types of products have to be labeled?
What is considered a “fresh” food?
What is a processed food?
What are Raw Agricultural Commodities (RACs)?
What is an imitation food?
Why doesn’t my food have a label?
What do the dates on food packages actually mean?
What are “conventional” foods?
What is “fair trade” food?
What does it mean if a food is made using “sustainable” practices?
What does “ethically sourced” mean?
What do food and diet fads mean when you see them on labels?
What does “humane” mean?

How accurate are food label claims? Which ones can I trust, and how do I know I can trust them?

Under the Federal Food, Drugs, and Cosmetic Act, labels cannot be false or misleading. FDA has the power to regulate labels to ensure that the information on the label does not deceive the consumer. However, label claims that are allowed by FDA can still be confusing—if they weren’t, this website wouldn’t be needed! The resources on this website are here to help you learn how to read food labels and understand the meaning of many of the labels you see. When label claims are regulated by FDA, you can feel confident the product meets the standards required for that claim, and if it doesn’t, you can report the product to FDA. For other label claims, you might consider doing a bit of research to understand how the company using the claim defines it. Extreme claims such as “cure-all” or “totally safe” should also be treated with caution. The nutrition panel and ingredients list are the most reliable sources for understanding the nutritional content or attributes of a product.

Uh oh! You're using an unsupported browser.

Labels 101

I. Regulated Voluntary Label Claims

II. Undefined Voluntary Label Claims

Frequently Asked Questions

How accurate are food label claims? Which ones can I trust, and how do I know I can trust them?

Does a food label have to be approved before it is used?

What types of products have to be labeled?

What is considered a “fresh” food?

What is a processed food?

What are Raw Agricultural Commodities (RACs)?

What is an imitation food?

Why doesn’t my food have a label?

What do the dates on food packages actually mean?

What are “conventional” foods?

What is “fair trade” food?

What does it mean if a food is made using “sustainable” practices?

What does “ethically sourced” mean?

What do food and diet fads mean when you see them on labels?

What does “humane” mean?