US import compliance

Labeling imported food for the United States

A consignment can be safe, correctly filed and fully documented, and still be refused because of what is printed on the pack. US labeling is prescriptive about wording, units and position, and a label built for the EU will not pass unchanged.

Last reviewed: September 22, 2026

01

What must appear

Review these principal retail label elements against the product and package concerned. Specific exemptions and placement rules may apply, including for nutrition labeling and small packages.

Mandatory label elements - 21 CFR Part 101
Element	Where it goes
Statement of identity	Principal display panel - the common or usual name of the food
Net quantity of contents	Principal display panel, in the bottom 30 %, in lines generally parallel with the base of the container
Ingredient list	Information panel - descending order of predominance by weight
Allergen declaration	Information panel - see section 3
Name and place of business	Information panel - of the manufacturer, packer or distributor
Nutrition Facts	Information panel, in the current US format

02

Net quantity: confirm units and placement

Where net quantity is expressed as a weight or measure, the label must carry both metric and US customary units - grams, kilograms, milliliters or liters alongside ounces, pounds or fluid ounces. One or the other is not sufficient.

For a retail package subject to dual-unit requirements, a declaration such as Net Wt 14.1 oz (400 g) illustrates both systems. Validate the conversion, type size and placement for the actual package; a commercial pack-size listing is not a completed label review.

03

The nine major allergens

Sesame became the ninth major food allergen under the FASTER Act, and all major-allergen requirements have applied to it since January 1, 2023. A label printed to an older specification is out of date.

Milk, eggs, fish and crustacean shellfish
Tree nuts, peanuts, wheat and soybeans
Sesame - since January 1, 2023

Review allergen-derived ingredients as well as named allergens. Exclusions, including those for certain highly refined oils, must be assessed against the actual ingredient and applicable FDA requirements.

04

Country of origin

Country of origin marking sits with US Customs under the Tariff Act of 1930, separately from FDA label rules, so it is easy to treat as another party’s responsibility and then get wrong.

The statement must be conspicuous. Where a US firm name and address appears as the party responsible for distribution, the country of origin must appear in close proximity to that name and address, and in lettering at least comparable in size.

The common failure: a US distributor address printed large on the information panel, with Product of set small somewhere else on the pack. That is a marking violation even when the origin is stated truthfully.

05

Where imported labels fail

Single-unit net quantity carried over from EU artwork.
Net quantity in the wrong position - outside the bottom 30 % of the front panel.
Sesame not declared on artwork approved before 2023.
Origin statement too small, or too far from the US distributor address.
An EU-format nutrition table (per 100 g only) instead of the US Nutrition Facts panel.
Ingredient names that are not the US common name for the ingredient.
Artwork signed off before the recipe was final - the most expensive version of all of these, because the pack is already printed.

06

How we handle it

Pack sizes reviewed in metric and US customary units where applicable before artwork approval
Allergen position taken from the formulation, including allergen-derived ingredients, and reviewed against the current nine
Artwork reviewed against US requirements at proof stage, before print - while corrections can still be made before packaging is printed
Origin, statement of identity and responsible-party wording agreed with the buyer rather than assumed

Source and scope

Source. 21 CFR Part 101 and the FDA Food Labeling Guide; the FASTER Act for sesame; country of origin marking under the Tariff Act of 1930, administered by US Customs and Border Protection. FDA: Food Labeling Guide. FDA: food allergens. The FDA notes that the guide chapters on allergens and nutrition are under revision; use the current resources linked from its guidance page for those requirements.

Scope. General information for commercial importers, not legal advice, and not a substitute for a labeling review of your specific artwork. Requirements differ by product type and change over time; confirm the current position before printing.

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