Utah Department of Agriculture and Food

Common Labeling Errors

This email address is being protected from spambots. You need JavaScript enabled to view it., Labeling Specialist
(801) 860-7075 or (801) 538-7124
(801) 538-4949 fax

  1. All packaged products must have a complete and correct label before being offered for sale. This includes the common or usual name of the product; name and address of the producer, manufacturer, or distributor; a net quantity statement; and an ingredient statement (unless it is a single ingredient product).

  2. All ingredients must be listed by their common or usual name in descending order of predominance by weight (from heaviest to lightest). Any ingredient which itself contains two or more ingredients:
    1. shall declare the common or usual name of the ingredient followed by a parenthetical listing of all ingredients contained therein in descending order of predominance;
    2. or by incorporating into the statement of ingredients in descending order of predominance in the finished food, the common or usual name of every component of the ingredient without listing the ingredient itself. (Use only one of these formats per label please.)

  3. The words "may contain" are only to be used in compliance with 21 CODE OF FEDERAL REGULATIONS (CFR) 101.4 (b), for example the allowance for fats/oils to be listed with "may contain" ______, _____, and/or ______ oils" when a manufacturer is unable to adhere to a constant pattern or fats or oils in the product. List each fat and oil by its common name, i.e. corn oil, cottonseed oil, beef fat, etc. Fats and oils that are fully or partially hydrogenated must indicate it by use of the words "hydrogenated" or "partially hydrogenated" before the kind of oil is listed.

  4. Labels intended for one product cannot be used to label a different product (i.e. a plain cheesecake label cannot be used for a cheesecake with a fruit topping; writing topping flavor on the ingredient statement is not sufficient. Nor is it correct to use an apple pie label on a cherry pie and write the word "cherry" on label.)

  5. Recipe or ingredient substitutions without correct labeling for new combination is prohibited (i.e. using Muenster cheese in a sandwich or salad whose label indicates the presence of Swiss cheese). Labels must correctly represent the product in the package.

  6. Sandwiches must include the ingredients for the bread as well as the other makings, meats, cheeses, condiments, lettuce, tomatoes, pickles, etc.

  7. Bulk self-service bins (whether candy, bakery, etc.) must list all ingredients in each product in type no smaller than 1/8 inch based on the height of the lower case letter "o" for the type style used if both upper and lower case letters are used, or 1/8" in height when using all upper case letters.

  8. "Thank You" labels in lieu of correct labels with all required information are prohibited. Unlabeled packaged product cannot be offered for sale.

  9. Covering or obscuring required label information by covering it with store stickers or coupons creates a misbranded product.

  10. Full service counters must have complete, correct ingredient information available for all products, so that if any customer should ask questions about the ingredients in any product, those questions can be answered completely and accurately.

  11. Net Quantity Statements and Method of Sale must be appropriate for the type of item sold (i.e. weight or count, fluid measurement, volume or area measurement, etc.)
    1. Labeling of net quantity must be clear, bold, conspicuous, legible and correct for both standard pack packages (i.e. each package of cheese is labeled 2 pounds and sold for $8.00);
    2. or random weight packages (i.e. New York Steak selling for $7.98 per pound and labeled with different net weight in each package, same price per pound, total computed price based on weight of individual package.)