Determine if your food brand qualifies for the FDA Small Business Nutrition Facts Exemption under 21 CFR 101.9(j)(18) or if retail/Amazon distribution requires a full panel.
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| Mandatory Nutrient | Raw Input | FDA Rounded Label Value | 2026 %DV | FDA Standard Rounding Rule Applied |
|---|
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Under 21 CFR 101.9(j)(18), low-volume food products sold by businesses with fewer than 100 full-time equivalent employees and fewer than 100,000 units sold in the US annually (or firms with <$50,000 food sales / <$500,000 total sales) can qualify for an exemption—provided the package makes zero nutrient content or health claims.
| Exemption Path | Employee / Sales Cap | FDA Filing Required? | Voided By Nutrient Claims? |
|---|---|---|---|
| 21 CFR 101.9(j)(1) Micro-Retailer | < $50,000 food sales OR < $500,000 total sales to consumers | No FDA notice required | Yes — any claim requires Nutrition Facts |
| 21 CFR 101.9(j)(18) Low-Volume | < 100 FTE employees AND < 100,000 units of product/year | Yes (unless US manufacturer with <10 FTEs & <10,000 units) | Yes — any claim requires Nutrition Facts |
According to FDA guidance, a truthful 'Gluten-Free' claim meeting 21 CFR 101.91 is not a nutrient content claim and does not by itself trigger mandatory Nutrition Facts, whereas 'Sugar-Free', 'Low Carb', or 'Good Source of Fiber' DO trigger mandatory Nutrition Facts.
Every food package must still display the Statement of Identity, Net Quantity of Contents (oz/g), Ingredient List in descending order of weight, Major Food Allergens (FASTER Act 9 allergens), and Name & Place of Business.
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