Breaking Down the Nutrition Facts Panel (NFP)

Everyone is familiar with seeing the (NFP) on packaged foods, but fewer people know about the history of the NFP and the requirements for creating one. This standardized label is a powerful tool for conveying nutritional information to consumers informing them about what they choose to eat and enabling them to make informed dietary decisions. Consider this article Nutrition Facts Panel 101. Let’s get into it.

A Brief History

The story of the NFP begins with the Nutrition Labeling and Education Act (NLEA) of 1990. This act mandated nutrition labeling for most food products. Prior to this, including nutritional information on food products was essentially optional. Until the enactment of the NLEA in 1994, an NFP was only required if a food had added vitamins, minerals, or protein, or if there was a nutrition claim made on its packaging or in its advertisements.

“There is significant consumer interest that the labels of standardized foods bear complete information on the ingredients contained in the food. In the absence of legal authority to require that the label bear such information, the Food and Drug Administration encourages all manufacturers, packers, and distributors to voluntarily make such disclosure.” Federal Register Vol.42—No.50 3-15-77 pg. 14311

With the NLEA, the FDA was granted the legal authority it needed to require NFPs on food products. The first standardized version of the Nutrition Facts Panel appeared in 1994. In 2016, the FDA announced major updates to the NFP, reflecting new developments in nutrition research, public health priorities, and public input. These changes, which were enacted on January 1, 2020, aimed to make it easier for consumers to make informed food choices and to promote healthier eating habits. The most notable changes included:

• Removing “Calories from fat” from the NFP
• Requiring declaration of “added sugars” in the Carbohydrates section
• Updating the list of vitamins and minerals that have to be included in the NFP to aid in public health priorities
• Making the calorie count larger and bolded
• Removing the footnote table that listed reference values used for calculating the percent daily value for certain nutrients for 2,000 and 2,500 calorie diets.

For the full list of changes, including public comments and FDA responses to comments, see here: Food Labeling: Revision of the Nutrition and Supplement Facts Labels | Posted by the Food and Drug Administration on May 27, 2016For a concise overview of the changes, see here: Changes to the Nutrition Facts Label | FDA

Key Components of the NFP

With a bit of background on the history of the NFP, let’s get into the details of what it contains and some of the most important rules for creating an NFP that complies with FDA guidelines.

All food labeling rules are extensively laid out in Part 101 (Food Labeling) of Title 21 (Food and Drugs) of the Code of Federal Regulations. Throughout this article there will be references to specific subcomponents of these regulations, listed in the following way for example:  21 CFR 101.9. Most of the Nutritional Facts Panel regulations can be found in that particular section (21 CFR 101.9), titled “Nutrition labeling of food.”

Serving Size & Servings Per Container

The very top of the NFP details the serving size and the number of servings per container. The serving size is the basis for all of the nutritional values on the NFP. It is this serving size that the rest of the values on the NFP are based on. The serving size is based on Reference Amounts Customarily Consumed (RACC). RACC is the amount of food customarily consumed per eating occasion that the FDA has specified for 133 food product categories (see 21 CFR 101.12(b)).

It is important to remember that the serving size is not a recommendation of how much to eat, but rather the amount that is typically eaten. If you eat twice the serving size, you're also consuming twice the calories and nutrients listed. The "servings per container" indicates how many of these servings are in the entire package.

Nutrient List

The main body of the Nutritional Facts Panel is mostly focused on macronutrients. Macronutrients are the nutrients our bodies need in larger amounts: carbohydrates, protein, and fats. Fats and carbohydrates both include subcomponents that must also be specified on the NFP. For fat these are Saturated Fat and Trans Fat. For carbohydrates these are fiber (“Dietary Fiber”) and also sugar (“Total Sugars”), which includes a specification for Added Sugars too. Companies may also choose to list monounsaturated and polyunsaturated fats in the Fats section and soluble and insoluble fibers in the Carbohydrates section, but these subcomponents are not required. Also included in the nutrient list are Cholesterol and Sodium, which are not macronutrients but are nevertheless important nutrients to be aware of.

Cholesterol is technically a type of fat (a.k.a. lipid), but because our bodies can produce it on their own–primarily in the liver and intestines–it’s actually not an essential nutrient.¹ An essential nutrient is any chemical necessary for bodily function that can not be produced by the body. The FDA used to put more emphasis on limiting cholesterol intake, but more recent research suggests that the link between cholesterol intake and cardiovascular disease (CVD) risk is relatively weak.² It is now better understood that older research linking cholesterol intake to CVD risk had more to do with the fact that foods that tend to be high in cholesterol also tend to be high in saturated fat and high levels of saturated fat in the diet are more definitively linked to CVD risk.³ Nevertheless, even the direct linkage of saturated fat intake to CVD risk is somewhat disputed.⁴

Sodium is a mineral and an essential nutrient. The Dietary Guidelines for Americans (a USDA report) recommends adults limit sodium intake to no more than 2,300 mg/day, however, researchers dispute this recommendation and a higher amounts, in the 4,000 to 6,000 mg range, are likely safe for most people, especially if you’re losing sodium via sweat from exercising and drinking plenty of water.⁵ Notably, inadequate sodium intake presents risks given its crucial role in the functioning of neurons and other cellular processes.⁶

Next to each nutrient there is the amount of it contained in a serving and a percentage value listed for the % Daily Value (%DV) column. The amounts are always in grams (g) for the macronutrients and milligrams (mg) for cholesterol and sodium (other units are used for some items in the vitamins and minerals section). For %DV, percentages are based on reference values for a standardized 2,000 Calories/day diet (see table below).

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%DV must be included for each nutrient except for Trans Fats, Protein (in most cases), and Total Sugars.⁷

‍Trans Fats: health experts and the FDA recommended that trans fats be avoided entirely because of the risk that they pose to cardiovascular health. It used to be the case that some food contained artificial trans fats from partially hydrogenated oils (almost always vegetable oils). However, in 2015, the FDA made a ruling deeming that partially hydrogenated oils were no longer “generally recognized as safe” (GRAS).⁸ Beginning in 2020, food manufacturers were no longer allowed to sell foods containing partially hydrogenated oils. This effectively banned trans fats, however, there are still some naturally occurring trans fats that typically exist in small amounts in some animal protein sources like steak, for example.

Protein: A %DV is required if a claim is made for protein on the packaging of the food, like "high in protein" or if a product is intended for infants and children under 4 years old. In most other cases, a %DV for protein is not required. However, if a food manufacturer chooses to include %DV for protein, as there is a Daily Reference Value (DRV) of 50 grams of protein for a 2,000 Calorie diet⁹ , then this percent must be based on the protein digestibility-corrected amino acid score (PDCAAS) of the food. Full details specifying whether or not a %DV statement is needed for protein can be found in 21 CFR 101.9(c)(7).

Total Sugars: “No Daily Reference Value has been established for Total Sugars because no recommendations have been made for the total amount to eat in a day. Keep in mind that the Total Sugars listed on the Nutrition Facts label include naturally occurring sugars (like those in fruit and milk) as well as Added Sugars.” That is from the FDA’s How to Understand and Use the Nutrition Facts Label page. Despite this, there is however, a daily reference value for Added Sugars of 50 grams, meaning that a healthy diet should not contain more than 50 grams of added sugars in a given day. Thus, for a food with 10 grams of added sugars, 20% needs to be listed as well.

Micronutrients

Micronutrients are vitamins and minerals that our bodies need in smaller amounts. The NFP must include the quantities and %DV for vitamin D, calcium, iron, and potassium. This was a part of the aforementioned changes to the NFP that were introduced in 2016. Previously, Vitamin A, Vitamin C, Calcium, and Iron were the two vitamins and two minerals that were required in NFPs. This change of requirements was based on a re-assessment of the most common nutritional deficiencies among Americans.¹⁰

If a food contains added vitamins and minerals then these must be stated. This is often the case for foods made from grains and flours like breads and cereals. “Enriched” or “fortified” flours are common primary ingredients in many breads and cereals; this means that various vitamins and minerals were added to the flours to increase their nutritional value. This is why the list of vitamins and minerals on many bread and cereal products are longer.

Manufacturers may voluntarily list other vitamins and minerals too. If there are micronutrients that are not artificially added to the food product but naturally occurring in its ingredient(s) companies can choose to communicate this to consumers. The NFP below, for example, comes from a package of organic almonds from foods alive. They chose to include Vitamin E and Magnesium in their NFP, which almonds are a good source of.

Formatting

The FDA provides flexibility in the layout of the NFP, while still ensuring that the required information is present and displayed clearly. The main two variations are the vertical and tabular formats, with the vertical being most common. For small packages, the linear or tabular formats are recommended. Another format is the aggregate display, which is used for foods that come in variety packs. Source of Images: 21 CFR 101.9(d)

Box: The nutrition information must be set off in a box using hairlines.  
Color & Background: It should be printed in all black or one color type on a white or other neutral contrasting background whenever practical.  
Type Style (Font): A single easy-to-read type style must be used.
Case: Generally, upper and lower case letters must be used.
Font Sizes (Minimums):

• Title ("Nutrition Facts"): Must be set in a type size larger than all other print in the nutrition label, except for the numerical calorie value.  
• "Calories" (Word): Must be bold or extra bold and no smaller than 16 point (except 10 point in specific cases).  
• Calories (Number): Must be bold or extra bold and no smaller than 22 point (except 14 point in specific cases).  
• "Serving size" & "Servings Per Container": "Serving size" must be bolded. Both are typically required to be no smaller than 10 points (9 points in some alternative formats). "Serving size" can be 8 points if space is limited.  
• Other Text: "Amount per serving," "% Daily Value*" headings & Main Nutrient Values must be no smaller than 8 points.  
• Vitamins/Minerals list & Footnote: No smaller than 6 point.  
• Small Packages (<12 sq. in.): Can use 6 point or all upper-case 1/16 inch minimum height.

Spacing & Alignment:

• Leading (Line Spacing): At least one point of leading (space between lines of text) is generally required. At least four points of leading must separate the main nutrient block (Calories through Protein) from the Vitamin/Mineral block below it. Letters should never touch.  
• Alignment:
  
  • "Nutrition Facts" title: Generally set to the full width of the box.  
  • "Serving size" / "Servings Per Container": Left-aligned. Serving size amount should be right-justified if space permits.  
  • Nutrient Names: Left-aligned in a column.  
  • Quantitative Amounts (g/mg/mcg): Can be right-aligned next to the nutrient name or in a separate column to the right.  
  • "% Daily Value*": Presented in a column aligned to the right, under the "% Daily Value*" heading.  

Highlighting & Rules:

• Highlighting (Bold/Extra Bold): Used to distinguish key elements like the "Nutrition Facts" title, "Serving size" declaration, "Calories" declaration (word and number), "% Daily Value*" heading, names of nutrients that are not indented (e.g., Total Fat, Cholesterol, Sodium, Total Carbohydrate, Protein), and the %DV numbers. No other information should be “highlighted.” Reverse printing (white text on black) is not permitted for highlighting.  
• Hairlines/Bars: Hairlines enclose the box. Centered hairlines separate individual nutrient lines. Heavier bars separate key sections: below servings information, below the main nutrients (before vitamins/minerals), and below the vitamin/mineral list (before the footnote). Light bars separate column headings ("Amount Per Serving" / "% Daily Value*") from the listings below them.  

These rules ensure the Nutrition Facts panel is presented consistently and legibly to consumers. Exemptions and modifications exist for specific situations like small packages, dual-column labeling, or dietary supplements.

Rules About Rounding

Calories out to be rounded to the nearest 5-calorie increment up to and including 50 calories, and 10-calorie increment above 50 calories. Amounts less than 5 calories may be expressed as zero.

Nutrients

• Fats: “Amounts shall be expressed to the nearest 0.5 (1⁄2) gram increment below 5 grams and to the nearest gram increment above 5 grams. If the serving contains less than 0.5 gram, the content shall be expressed as zero.”
• Cholesterol: “A statement of the cholesterol content in a serving expressed in milligrams to the nearest 5-milligram increment, except that label declaration of cholesterol information is not required for products that contain less than 2 milligrams cholesterol in a serving and make no claim about fat, fatty acids, or cholesterol content, or such products may state the cholesterol content as zero.”
• Sodium: If there is less than 5 mg of sodium in a serving, 0 mg can be stated in the NFP. Otherwise, the amount of sodium should be stated “to the nearest 5-milligram increment when the serving contains 5 to 140 milligrams of sodium, and to the nearest 10-milligram increment when the serving contains greater than 140 milligrams.” 21 CFR 101.9(c)(4)
• Carbohydrates: “A statement of the number of grams of total carbohydrate in a serving expressed to the nearest gram.” If a serving contains less than 0.5 grams of total carbohydrates then 0 g can be listed. This same rule applies for the subcomponents of Total Carbohydrates (i.e., Dietary Fiber, Total Sugars, and Added Sugars).
• Protein: Similar to carbohydrates, protein quantity ought to be expressed to the nearest gram, however, if a serving contains less than 0.5 grams of protein, the quantity can be expressed as zero.
• Vitamins and Minerals: There does not appear to be a rule about rounding the quantity of vitamins and minerals, however, there is a rule for rounding the %DV for vitamins and minerals. %DV is rounded “to the nearest 2-percent increment up to and including the 10-percent level, the nearest 5-percent increment above 10 percent and up to and including the 50-percent level, and the nearest 10-percent increment above the 50-percent level.” 21 CFR 101.9(c)(8)(iii)

The number of servings ought to be rounded to the nearest whole number except for when the number of servings is between 2 and 5 and for random weight products. The number of servings between 2 and 5 servings is rounded to the nearest 0.5 serving.

Due to these rounding guidelines, nutritional labeling has a certain degree of imprecision. Nonetheless, they help strike a balance between the burden of accuracy on the producer and the ease of interpretation for the consumer.

Conclusion

The Nutrition Facts Panel is a tool that empowers consumers to make informed choices about the foods they eat. By understanding serving sizes, macronutrients, micronutrients, and how to interpret the label, consumers can use the NFP to support a healthy diet and reduce their risk of diet-related diseases. On the other hand, the Nutrition Facts Panel enables food companies to honestly and transparently reflect the nutritional content of their products. Importantly, this can help companies support certain claims they make about their products. All in all, the NFP is a valuable source of nutritional truth that enables transparency and accountability. As consumers pay more attention to their food choices, the overall importance of the NFP and the underlying assumptions and choices behind the modern NFP's creation are likely to receive more scrutiny. Ultimately, the NFP is a compromise between policy goals and practical considerations.

Learn More

• Food Labeling Guide (PDF) | FDA - Unfortunately, this guide has not been updated to reflect the changes that went into effect in 2020, however, it is still a useful guide for many of the regulations that still persist.

• The Nutrition Facts Label | FDA  Interactive Nutrition Facts Label

• Scientific Report of the 2015 Dietary Guidelines Advisory Committee - This is the report that led to the 2016 changes in food labeling that came into effect in 2020.

• eCFR :: 21 CFR Part 101 -- Food Labeling - This is the part of the Federal Register that contains all of the food labeling rules, including everything that was covered here and a whole lot more.

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¹ https://www.sciencedirect.com/topics/medicine-and-dentistry/cholesterol-synthesis and https://www.accessdata.fda.gov/scripts/interactivenutritionfactslabel/cholesterol.cfm

²  https://www.ahajournals.org/doi/10.1161/CIR.0000000000000743

³ See footnote 5

⁴ https://www.lipidjournal.com/article/S1933-2874(21)00248-8/abstract

⁵ https://jamanetwork.com/journals/jama/fullarticle/1105553 and https://jamanetwork.com/journals/jama/fullarticle/899663

⁶ https://doi.org/10.3390/nu13093232, https://biobeat.nigms.nih.gov/2020/11/pass-the-salt-sodiums-role-in-nerve-signaling-and-stress-on-blood-vessels/, and https://www.mayoclinic.org/diseases-conditions/hyponatremia/symptoms-causes/syc-20373711

⁷  https://www.fda.gov/food/nutrition-facts-label/how-understand-and-use-nutrition-facts-label 

⁸ https://health.clevelandclinic.org/why-trans-fats-are-bad-for-you

⁹ https://www.ecfr.gov/current/title-21/part-101/section-101.9#p-101.9(c)(9)

¹⁰ https://www.federalregister.gov/d/2014-04387/p-131