New Jersey is home to hundreds of food manufacturers — from large processors along the Route 1 corridor to specialty food producers in Bergen County and craft beverage companies across Somerset and Hunterdon Counties. Every product that leaves a New Jersey facility and enters interstate commerce is subject to FDA food labeling requirements under 21 CFR Parts 101 through 104.
This isn’t a niche regulatory topic. The FDA issues warning letters and recalls for labeling violations routinely, and retailers increasingly scrutinize food labels for compliance before they’ll put products on shelves. Here’s what you need to know.
FDA’s food labeling regulations (21 CFR Part 101) require five elements on every packaged food product:
This is the common name of the food — what it is. It must appear on the principal display panel (PDP) in bold type, in a size “reasonably related” to the most prominent printed matter on the label. If a standard of identity exists for the food (e.g., “ketchup,” “peanut butter”), the product must meet that standard or use a different name.
Declared in both metric and U.S. customary units on the PDP. For products under 1 pound, declare in both ounces and grams. For products over 1 pound, declare in pounds and ounces plus grams. Liquid products must declare in fluid ounces plus milliliters.
Placement: Must appear in the lower 30% of the PDP.
The responsible party’s business name and address (city, state, ZIP code). If the product is manufactured under a co-packing arrangement, the label may use language like “Manufactured for [brand]” or “Distributed by [distributor].“
Listed by their common or usual names, in descending order of predominance by weight. All ingredients must be listed, including sub-ingredients of complex ingredients (e.g., “butter (cream, salt)” — not just “butter”).
Spice, natural flavor, and artificial flavor can be declared without naming the specific components, but must use those terms.
The most complex element. FDA’s updated Nutrition Facts format (required since January 2020 for manufacturers with $10M+ in annual food sales; January 2021 for smaller manufacturers) includes:
For very small packages (total surface area less than 12 square inches), a simplified format with fewer nutrients can be used.
Under the Food Allergen Labeling and Consumer Protection Act (FALCPA) and the FASTER Act (2023), the following nine foods are major food allergens requiring specific declaration:
Major allergens must be declared either:
Cross-contact statements (“Made in a facility that also processes…”) are voluntary and not regulated, but food manufacturers use them to communicate risk to consumers with allergies.
Many NJ food manufacturers were caught off guard by the sesame requirement in 2023. If your product was formulated before that date, review your labels for sesame compliance.
The Fair Packaging and Labeling Act (FPLA) governs net quantity declarations. The key rules:
New Jersey has its own Weights and Measures Division that conducts package net content inspections. Underweight packages can result in state-level fines separate from FDA action.
Regulatory compliance on the label is one challenge; the label’s physical performance is another. FDA-compliant content on a label that fades in refrigeration, falls off during shipping, or becomes illegible after six months in a retail display is still a compliance failure in practice.
Materials for NJ food manufacturers:
For nutrition facts panels and ingredient lists — which must be legible at specified minimum type sizes (minimum 6 points for most formats, 4.5 points for simplified formats on small packages) — print quality matters enormously. At Certified Labeling Solutions, our Nilpeter flexographic presses hold registration tight enough to reproduce dense regulatory text cleanly at small point sizes.
Incorrect serving size: FDA updated serving sizes in 2016 to reflect amounts people actually consume. Legacy serving sizes (e.g., “1/2 cup” for ice cream when the reference amount is now 2/3 cup) must be updated.
Missing Added Sugars: The “Added Sugars” line in the updated Nutrition Facts format is commonly omitted by manufacturers who haven’t updated their label design since 2020.
Sesame omission: Post-FASTER Act compliance requires sesame to appear in allergen declarations for any product containing sesame or processed in a facility with sesame cross-contact risk (if the manufacturer chooses to declare it).
Wrong address format: The responsible party address must include street address, city, state, and ZIP code. Post office box numbers alone are not acceptable for domestic manufacturers.
Font size violations: The % Daily Value for calories must be listed at minimum 8-point type; the Nutrition Facts header at minimum 8-point; servings per container and calories at minimum 24 points.
FDA food labeling is detailed, and label real estate is finite. Fitting regulatory content, brand identity, and marketing claims onto a 3” × 4” label while remaining legible and compliant requires careful layout and precision printing. Certified Labeling Solutions has been producing FDA-compliant food labels for New Jersey manufacturers since 1986.
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