as breakfast cereals with milk. These labels have both nutrient lists as packaged and as prepared. A dual listing may also be used when there is an optional way to list the nutrients; for example, nutritional values based on 100 grams.9
Simplified Format
This format is allowed when the food contains insignificant amounts of eight or more of the mandatory nutrients and total calories. “Insignificant” means that a declaration of zero could be made in nutrition labeling, or, for total carbohydrate, dietary fiber, and protein, the declaration states “less than 1 g”.
For foods for children under 2, the simplified format may be used if the product contains insignificant amounts of six or more of the following: calories, total fat, sodium, total carbohydrate, dietary fiber, sugars, protein, vitamins A and C, calcium, and iron.
If the simplified format is used, information on total calories, total fat, total carbohydrate, protein, and sodium—even if they are present in insignificant amounts—must be listed. Other nutrients, along with calories from fat, must be shown if they are present in more than insignificant amounts. Nutrients added to the food must always be listed.
Food for Infants and Children
The labels of foods for children under 2 (except infant formula, which has special labeling rules under the Infant Formula Act of 1980) may not carry information about saturated fat, polyunsaturated fat, monounsaturated fat, cholesterol, calories from fat, or calories from saturated fat. This is to prevent parents from wrongly assuming that infants and toddlers should restrict their fat intake, when, in fact, they should not. Fat is important during these years to ensure adequate growth and development.
The labels of foods for children under 4 may not include the % DVs for total fat, saturated fat, cholesterol, sodium, potassium, total carbohydrate, and dietary fiber. They may, however, carry % DVs for protein, vitamins, and minerals. These nutrients are the only ones for which FDA has set DV for this age group.
Thus, the top portion of the “Nutrition Facts” panels of foods for children under 4 will consist of two columns. The nutrients’ names will be listed on the left and their quantitative amounts will be on the right. The bottom portion will provide the % DVs for protein, vitamins, and minerals. Only the calorie conversion information may be given as a footnote.
Small and Intermediate‐Size Packages
Packages with less than 12 square inches of available labeling space (about the size of a package of chewing gum) do not have to carry nutrition information unless a nutrient content or health claim is made for the product. However, they must provide an address or telephone number for consumers to obtain the required nutrition information.
Two modifications in format are allowed for intermediate‐sized packages, those between 12 and 40 square inches: the tabular and linear formats.10 These formats also allow for use of specified abbreviations and omitting all of the footnotes, except for the statement that “Percent Daily Values are based on a 2,000‐calorie diet.”
The tabular format (without abbreviations) is also permitted with packages with more than 40 square inches of labeling space if there is insufficient vertical space (about 3 inches) to accommodate the required vertical information.
Shortened Format11
For foods that contain certain nutrients at insignificant levels, the shortened format Nutrition Facts panel permits not listing those nutrients.
Aggregate Display
This is allowed on labels of variety‐pack food items, such as ready‐to‐eat cereals and assorted flavors of individual ice cream cups. With this display, the quantitative amount and % DV for each nutrient are listed in separate columns under the name of each food.
4.3.4 Serving Sizes
The serving size is the basis for reporting each food’s nutrient content. In the past, determination of the serving size was up to the discretion of the food manufacturer. Under NLEA, the serving sizes are more uniform and they must reflect the amounts people actually eat.
RACC
The serving size is based on the Reference Amounts Customarily Consumed (RACC). The FDA lists of “Reference Amounts Customarily Consumed Per Eating Occasion” are broken down into 139 product categories.12 The RACC regulation lists the amounts of food customarily consumed per eating occasion for each category based primarily on national food consumption surveys. The regulation also provides the suggested label statement for serving size declaration. For example, the category “breads, rolls” has a reference amount of 50 grams, and the appropriate label statement for sliced bread or roll is “___ piece(s) (___ g)” or, for unsliced bread, “2 oz (56 g/__ inch slice)”.
Discrete Units
When a food comes in discrete units, such as cookies, candy bars, and sliced products, the serving is generally the number of whole units that most closely approximates the reference amount. However, there are specific regulations on determining how many units make up a serving. There are four categories of discrete units:
50 percent or less of the RACC
More than 50 percent but less than 67 percent of the RACC
67 to 200 percent of the RACC
200 percent or more of the RACC
50 Percent or Less of the RACC13
If a unit weighs 50 percent or less of the reference amount, the serving size is the number of whole units that most closely approximates the reference amount for the product category. Cookies, for example, are under the “bakery products” category, and cookies have a reference amount of 30 grams. The household measure closest to that amount is the number of cookies that comes closest to weighing 30 grams. Thus, the serving size on the label of a package of cookies in which each cookie weighs 13 grams would read “2 cookies (26 g)”.
More Than 50 Percent but Less Than 67 Percent of the RACC14
If a unit weighs more than 50 percent, but less than 67 percent of the reference amount, the serving size may declare one unit or two units as the serving size.
67 to 200 Percent of the RACC15
If one unit weighs 67 percent or more but less than 200 percent of the reference amount, the serving size is one unit. For example, the reference amount for bread is 50 grams; therefore, the label of a loaf of bread in which each slice weighs
