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US import compliance

Labelling 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 labelling is prescriptive about wording, units and position, and a label built for the EU will not pass unchanged.

Last reviewed: 20 September 2026

01

What must appear

Six elements are mandatory on a retail food package. They are split across two areas of the pack, and the split is itself a rule.

Mandatory label elements - 21 CFR Part 101
ElementWhere it goes
Statement of identityPrincipal display panel - the common or usual name of the food
Net quantity of contentsPrincipal display panel, in the bottom 30 %, in lines generally parallel with the base of the container
Ingredient listInformation panel - descending order of predominance by weight
Allergen declarationInformation panel - see section 3
Name and place of businessInformation panel - of the manufacturer, packer or distributor
Nutrition FactsInformation panel, in the current US format

02

Net quantity: both systems, every time

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

This is where EU artwork fails most often. A European pack declares 400 g and stops. For the US it must read 400 g (14.1 oz), and sit in the bottom 30 % of the front panel rather than wherever the design left room. Every pack size on this site is published in both systems for exactly this reason.

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 1 January 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 A label printed to an older specification is out of date.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 1 January 2023

The declaration covers ingredients derived from an allergen, not only the allergen itself - a point that catches out products using sesame oil, or protein derived from a major allergen.

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 somebody else problem 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

  • Every pack size published in metric and US customary units, so the declaration is settled before artwork begins
  • 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 - the point at which a correction still costs nothing
  • 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.

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

Enquiries: sales@alphatradecorp.com

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