US Food Labeling Requirements 2026-2027

The United States has no warning seals. Its food label rests on the Nutrition Facts panel, the declaration of nine major allergens and the bioengineered food disclosure, all under FDA’s 21 CFR Part 101. But 2026 and 2027 bring three changes that land squarely on the package: Red No. 3 must be out of food by January 15, 2027, the new “healthy” definition carries a February 2028 compliance date, and a proposed front-of-package rule is still waiting to be finalized.

Part of our series on food labeling requirements market by market.

Who regulates what: FDA, USDA and TTB

The first question is not what the label says, but who polices it. In the United States, food labeling authority is split across three agencies:

Agency	Scope
FDA (Food and Drug Administration)	The vast majority of packaged foods, under the Federal Food, Drug, and Cosmetic Act and 21 CFR Part 101.
USDA — FSIS and AMS	FSIS regulates meat, poultry and egg products. AMS administers the National Bioengineered Food Disclosure Standard.
TTB (Alcohol and Tobacco Tax and Trade Bureau)	Alcoholic beverages.

A processed meat product and a cookie do not answer to the same regulator or the same rulebook. Before the artwork starts, the product has to be placed in the right lane.

Mandatory elements of every label

For FDA-regulated foods, 21 CFR Part 101 organizes the information across two zones of the package: the principal display panel (PDP), the face the shopper sees on shelf, and the information panel, normally the panel immediately to its right.

On the PDP:

Statement of identity: the common or usual name of the food, in prominent type and generally in a line parallel to the base of the package.
Net quantity of contents, placed in the bottom 30% of the panel and declared in both metric and US customary units.

On the information panel:

Nutrition Facts.
Ingredient list, in descending order of predominance by weight.
Allergen declaration.
Name and place of business of the manufacturer, packer or distributor. If the firm is not the manufacturer, the statement must be qualified — “Manufactured for” or “Distributed by”.

All of it in English. A bilingual label is allowed, but English is not optional: every piece of mandatory information must appear in English.

The Nutrition Facts panel

The current format comes from the 2016 final rule and is now mandatory for all manufacturers. What sets it apart from the older panel:

Calories in noticeably larger type.
Mandatory declaration of added sugars, in grams and as a percent Daily Value.
Updated Daily Values.
Mandatory declaration of vitamin D and potassium, alongside calcium and iron. Vitamins A and C are no longer required.
Serving sizes based on what people actually eat, and a dual-column format — per serving and per package — for products that can reasonably be consumed in one sitting.

The nine major allergens

FALCPA established eight major food allergens, and the FASTER Act of 2021 added sesame as the ninth, effective January 1, 2023. The full list: milk, egg, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame.

There are only two acceptable ways to declare them: in parentheses within the ingredient list, or in a separate “Contains” statement placed immediately below the ingredient list.

Bioengineered food disclosure

The National Bioengineered Food Disclosure Standard, administered by USDA’s Agricultural Marketing Service, has been mandatory since January 1, 2022. Disclosure can be made through text, the official “bioengineered” symbol, an electronic or digital link with a scan instruction, or a text-message option.

For the package designer this has one practical consequence: the scannable option spares artwork real estate, but it commits the brand to keeping that digital destination alive for the full commercial life of the product.

What importing adds on top

A compliant label is not enough. Placing food on the US market carries obligations that travel with the shipment, and they routinely catch first-time exporters off guard:

Food facility registration with FDA, renewed biennially.
Prior Notice to FDA for every imported food shipment.
FSVP (Foreign Supplier Verification Program): the US importer must verify that the foreign supplier produces the food under standards equivalent to those required in the United States, and must be identified in the customs entry.

What changes in 2026 and 2027

Red No. 3: out by January 15, 2027

On January 15, 2025, FDA issued the order revoking the authorization of FD&C Red No. 3 in food and ingested drugs, acting under the Delaney Clause of the FD&C Act, which bars FDA from authorizing a color additive found to induce cancer in humans or animals. The deadlines are firm: January 15, 2027 for food and beverages, and January 18, 2028 for ingested drugs. After those dates FDA will no longer certify the dye, and any new lot containing it is deemed adulterated. The colorant showed up mostly in candy, cakes, cookies, frozen desserts and frostings.

This is the hardest date on the calendar, because it cannot be solved by changing copy. It forces reformulation and, almost always, new artwork — the product itself changes color. Some manufacturers are moving ahead of the deadline; Nestlé USA committed to eliminating FD&C colors by mid-2026.

“Healthy”: redefined, with a 2028 compliance date

FDA published the final rule redefining the “healthy” nutrient content claim on December 27, 2024. Under the new framework, a food qualifies only if it delivers a minimum amount from a food group — vegetables, fruits, dairy, grains, protein or oils — while staying under limits for added sugars, saturated fat and sodium. The effective date was pushed to April 28, 2025 under the January 2025 regulatory freeze, but the compliance date did not move: February 25, 2028. Early adoption is permitted from the effective date onward.

Front-of-package: proposed, not in force

On January 16, 2025, FDA published the proposed rule on Front-of-Package Nutrition Information, which would make a standardized “Nutrition Info box” mandatory on the front of most packaged foods. The box would call out saturated fat, sodium and added sugars, each rated low, medium or high based on percent Daily Value.

The comment period, originally set to close in May 2025, was extended to July 15, 2025. FDA listed the rule among its 2026 priority deliverables and at one point projected a final rule by May of that year. As of this article, no final rule has issued. The proposed compliance timeline is three years from the effective date for firms with USD 10 million or more in annual food sales, and four years for firms below that threshold.

This deserves to be stated precisely, because there is a lot of confusion in the market: no packaged food in the United States is currently required to carry nutrition information on the front of the pack. What exists is a proposal whose clock has not started.

What it means for the package

The front is still free, and that will not last forever. Unlike Colombia, Peru or Chile, the US principal display panel only has to carry the name of the food and the net quantity. The informational load lives on the side panel. If the front-of-package rule is finalized, a box with three rated nutrients moves onto the main face, with a three- or four-year runway. Anyone redesigning a US portfolio in 2026 should be reserving that space now rather than retrofitting it later.

Red No. 3 is a reformulation project, not a labeling one. January 2027 is close for a chain that involves reformulating, validating color stability and shelf life, correcting the ingredient statement and adjusting artwork to the product’s new shade. Printed material inventories need to be planned against that date.

For a Latin American exporter, the United States is a separate artwork. There is no way to serve Bogotá and Miami with the same package: the language, the nutrition declaration system, the allergen logic and the units all change. What can be shared is the architecture — same brand, same visual hierarchy, same color system — with panels swapped by market. That is the difference between managing two artworks and managing two brands.

Frequently asked questions

Does the United States require warning labels like Colombia or Peru?

No. There is no front-of-package warning requirement in force. A rule for a front-of-package informational box has been proposed since January 2025, but it has not been finalized.

Can I use a bilingual Spanish-English label?

Yes, as long as all mandatory information appears in English. Spanish may accompany it, never replace it.

Does sesame always have to be declared?

Yes. Since January 1, 2023, sesame is the ninth major allergen and must be declared whenever it is present as an ingredient, exactly like the other eight.

What happens to products with Red No. 3 made before January 2027?

Product manufactured before the effective date can still be found on the market; what ends is the ability to manufacture with the dye once the deadline passes.

Who answers to FDA for an imported product’s label?

Responsibility falls on whoever introduces the product into US commerce. The importer must also comply with FSVP and be identified in the customs entry, and every shipment requires Prior Notice.

References

U.S. Food and Drug Administration. 21 CFR Part 101 — Food Labeling, and Food Labeling Guide. FDA
Federal Register. Food Labeling: Front-of-Package Nutrition Information, proposed rule published January 16, 2025. Read the document
U.S. Food and Drug Administration. Front-of-Package Nutrition Labeling. FDA
Federal Register. Food Labeling: Nutrient Content Claims; Definition of Term “Healthy”, final rule of December 27, 2024. Read the document
Federal Register. Delay of the effective date of the “healthy” final rule to April 28, 2025. Read the document
U.S. Food and Drug Administration. FD&C Red No. 3 — revocation of authorization and compliance deadlines. FDA
U.S. Food and Drug Administration. FDA encourages food manufacturers to accelerate phasing out use of FD&C Red No. 3 ahead of the 2027 deadline. FDA
U.S. Food and Drug Administration. Food Allergies — FALCPA and the FASTER Act; sesame as the ninth major allergen since January 1, 2023. FDA
USDA Agricultural Marketing Service. National Bioengineered Food Disclosure Standard. AMS

Reference article updated on August 29, 2026. US labeling rules are in motion: before locking artwork, check the current status of each rule in the Federal Register and on FDA’s website.

By: Eng. Iván H. Rodríguez B. — 40 years in the packaging industry. Director of Envapack.com.

US Food Labeling Requirements: What Changes in 2026 and 2027