FDA Ingredient List Requirements

Key Rules

The FDA requires ingredient lists to follow these rules under 21 CFR § 101.4:

• Ingredients must be listed in descending order by weight before processing
• Each ingredient must use its common or usual name — not a brand or marketing name
• Sub-ingredients within compound ingredients must be listed in parentheses
• The ingredient list must appear on the information panel (usually the side or back of the package)
• Incidental additives that have no functional purpose in the finished product may be omitted
• Spices, flavorings, and colorings can be declared collectively unless they are also major allergens

Examples

Simple ingredient list

Ingredient list with sub-ingredients

When a compound ingredient (like chocolate chips) makes up less than 2% of the finished product, you may list only the compound ingredient. Otherwise, sub-ingredients must appear in parentheses directly after the compound ingredient.

Flavors, spices, and colors

Common Mistakes

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  Listing ingredients alphabetically or in any order other than descending weight
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  Using brand names (e.g. "Nutella") instead of common ingredient names
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  Omitting sub-ingredients for compound ingredients that make up more than 2% of the product
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  Not declaring colorings that are also major allergens (e.g. FD&C Yellow 5 must always be named individually)
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  Placing the ingredient list on the principal display panel instead of the information panel
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  Using tiny type — the ingredient list must meet FDA minimum font size requirements

Related Requirements

Ingredient lists often interact with other FDA label rules. Make sure your label also complies with:

• FDA allergen labeling requirements — major allergens must be declared separately
• FDA font size rules — minimum type size applies to the ingredient list
• Nutrition Facts label format — typically appears on the same information panel