Guide 06 of 08 ยท American Samoa

Label Requirements in American Samoa

Every packaged food product sold in American Samoa must carry a compliant label. Here is exactly what must appear, how to format it, and what the territory's 2017 labeling guidelines require of home food sellers.

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American Samoa's 2017 Mandatory Labeling Guidelines

In 2017, American Samoa adopted mandatory national labeling guidelines for packaged foods and drinks โ€” the first territory-wide food labeling standard. These guidelines align with international Codex Alimentarius standards and apply to all packaged food products sold in the territory. Because there is no separate cottage food labeling exemption, home food sellers must comply with these general labeling requirements. The specific label elements below represent the minimum required under these guidelines, aligned with FDA food labeling standards applicable to American Samoa as a U.S. territory. View territorial regulations โ†’

What Must Appear on Every Label

These seven elements are required on every packaged food product sold commercially in American Samoa. Missing any one of them puts you out of compliance with the 2017 labeling guidelines and FDA labeling requirements applicable to the territory.

1
Required
Product Name (Common or Usual Name)
The label must display the common or usual name of the food in a prominent position on the principal display panel โ€” the front face of the package that is most likely to be seen by the consumer. The name must accurately describe the food. You cannot call a jam a "spread" if it meets the standard of identity for jam, or use a misleading name that implies a different product than what's inside.
Examples
"Guava Jam" ยท "Coconut Toffee" ยท "Koko Samoa Drinking Powder" ยท "Panikekes Mix" ยท "Passion Fruit & Ginger Shrub Concentrate"
2
Required
Net Weight or Net Volume
The net quantity of contents must appear on the principal display panel in the lower 30% of the panel. It must be declared in both metric (grams/milliliters) and U.S. customary units (ounces/fluid ounces) for most packaged foods. This is the weight of the food itself โ€” not including the container. For liquids, declare fluid ounces and milliliters. For solids, declare ounces (avoirdupois) and grams.
Examples
Solid: Net Wt 8 oz (227 g) ยท Liquid: Net 8 fl oz (237 mL) ยท Small unit: Net Wt 1.5 oz (42 g)
3
Required
Ingredient List
All ingredients must be listed on the information panel (the side or back of the package) in descending order by weight โ€” the ingredient present in the greatest amount by weight is listed first. Each ingredient must be identified by its common name. Sub-ingredients of a compound ingredient (e.g., chocolate chips) can be listed parenthetically: chocolate chips (sugar, cocoa butter, chocolate, vanilla extract).
Example โ€” Guava Jam
Ingredients: Guava, sugar, pectin, citric acid, lemon juice.
Example โ€” Coconut Toffee
Ingredients: Sugar, butter (cream, salt), coconut flakes, corn syrup, salt, vanilla extract.
4
Required
Allergen Disclosure
The nine major food allergens must be declared whenever they are present in the product โ€” either as an ingredient or as a component of a compound ingredient. Allergen declaration must use one of two FDA-approved formats: (1) listed in parentheses within the ingredient list โ€” flour (wheat) โ€” or (2) in a separate "Contains:" statement immediately following the ingredient list.
Contains Statement Example
Contains: Wheat, milk, tree nuts (coconut).
5
Required
Seller Name & Address
The name and place of business of the manufacturer, packer, or distributor must appear on the label. For home food sellers, this is your business name and your business address (or mailing address, if you don't want to publish your home address โ€” a P.O. Box in Pago Pago is acceptable as a contact address). If operating under a business name different from your personal name, the business name as registered with ASDOC should appear.
Example
Produced by Mele's Kitchen ยท P.O. Box 1234, Pago Pago, AS 96799
6
Required
Best-By or Use-By Date
While U.S. federal law does not universally mandate date labeling for all packaged foods, American Samoa's 2017 mandatory labeling guidelines aligned with Codex standards generally require a durability date โ€” either a "best before" (quality) or "use by" (safety) date โ€” on packaged foods. For home food sellers, a "Best By" date is the standard practice. It should reflect realistic shelf life under typical Pacific storage conditions โ€” not optimistic mainland estimates. Test your product's actual shelf life in your kitchen environment before committing to a date.
Examples
Best By: 15 SEP 2026 ยท Best Before: September 15, 2026
7
Required
Production or Lot Identifier
A lot code or batch identifier allows you to trace any product back to its production batch. This is critical for recalls โ€” if a specific batch has a problem, you need to identify which units are affected without pulling all inventory. The lot code can be simple: a date code or production batch number stamped or printed on the label or container.
Examples
Lot: 2026-04-05-A ยท Batch: 0405A ยท Lot Code: 260405 (YYMMDD format)

Sample Compliant Label โ€” Guava Jam

This annotated mock label shows how all required elements come together on a real product label for the American Samoa market.

โœ“ Compliant
๐Ÿƒ Mele's Guava Jam
Made in American Samoa ยท Small Batch
โ‘  Net Wt 8 oz (227 g)
โ‘ฅ Best By 15 SEP 2026
โ‘ฆ Lot 260405-A
โ‘ข Ingredients
Guava, sugar, pectin, citric acid, lemon juice.
โ‘ฃ Contains: No major allergens.
โš  Made in a home kitchen not routinely inspected by the Department of Health. This product is not intended to diagnose, treat, cure, or prevent any disease.
โ‘ค Mele's Kitchen
P.O. Box 1234, Pago Pago, AS 96799
meles.kitchen@email.com
โ‘ 
Product name on the principal display panel โ€” common name "Guava Jam" in prominent type, visible when facing the consumer.
โ‘ก
Net weight in both U.S. customary (oz) and metric (g), in the lower 30% of the principal display panel.
โ‘ข
Ingredient list in descending order by weight โ€” guava has the greatest weight, so it's listed first.
โ‘ฃ
Allergen disclosure โ€” this jam has no major allergens, but the statement should still be present to confirm awareness of the requirement.
โ‘ค
Business name and address โ€” registered business name and a P.O. Box to protect home address privacy while meeting the requirement.
โ‘ฅ
Best-by date โ€” clearly formatted, easy to read. Use a date that reflects actual tested shelf life in Pacific conditions.
โ‘ฆ
Lot code โ€” allows batch traceability. Format: YYMMDD-batch letter is simple and clear.
โš 
Home kitchen disclaimer โ€” because American Samoa has no cottage food exemption, include a statement noting the food was produced in a home kitchen. This is strongly recommended and matches best practice across cottage food-regulated jurisdictions.

Recommended Disclaimer Language for American Samoa

American Samoa has no official cottage food disclaimer statement โ€” because it has no cottage food law. However, including a home kitchen disclaimer on your label is strongly recommended as a matter of transparency and good practice. It mirrors the standard used in cottage food-regulated states and aligns with what ASDOH is likely to expect from a permitted home food seller.

Recommended Disclaimer Statement
Primary Recommended Wording
"Made in a home kitchen. This product has not been inspected by the American Samoa Department of Health."
This language clearly informs buyers that the product was made in a private home kitchen โ€” not a licensed commercial facility โ€” and that it has not undergone DOH inspection of the production facility. It is honest, accurate, and parallel to the disclaimer language used in cottage food-regulated states. Consult ASDOH directly to confirm whether they require a specific disclaimer text as part of your health permit conditions. View permit contact information โ†’
Alternative Formulations
More Detailed Version
"Produced in a home kitchen not routinely inspected by the American Samoa Department of Health. For questions, contact [your business name] at [contact info]."
Brief Version
"Home kitchen product โ€” not DOH inspected."
If Produced in Licensed Kitchen
"Produced in a licensed commercial kitchen. Permitted by the American Samoa Department of Health."
With Health Permit Number
"Produced under American Samoa DOH Health Permit No. [XXXX]."

The Nine Major Food Allergens

FDA's Food Allergy Labeling and Consumer Protection Act (FALCPA), updated by the FASTER Act (2023), requires that nine major allergens be declared on food labels. These federal requirements apply to packaged foods in American Samoa. Failure to declare an allergen can be grounds for a product recall and health permit action.

๐ŸŒพ
Wheat
Includes all forms of wheat โ€” flour, whole wheat, wheat starch, wheat germ. Present in most baked goods.
๐Ÿฅ›
Milk
Includes butter, cream, cheese, whey, casein. Present in many traditional Samoan baked goods using dairy.
๐Ÿฅš
Eggs
Whole eggs, egg white, egg yolk, albumin. Present in many cakes, custards, and baked goods.
๐Ÿฅœ
Peanuts
Peanuts and peanut-derived ingredients. Must be declared even in trace amounts from shared equipment.
๐ŸŒฐ
Tree Nuts
Must specify the exact nut: walnut, cashew, almond, macadamia, etc. Note: Coconut is a tree nut per FDA
๐ŸŸ
Fish
Must specify the species: tuna, snapper, mackerel. Highly relevant given American Samoa's seafood-rich cuisine.
Pacific relevance โ€” high
๐Ÿฆ
Shellfish
Must specify type: shrimp, crab, lobster, scallop. Relevant for any Pacific seafood-based products.
Pacific relevance โ€” high
๐ŸŒฑ
Soy
Soybeans and soy-derived ingredients including soy sauce, tofu, miso, edamame. Present in sapasui and many Asian-influenced Samoan dishes.
๐Ÿซ˜
Sesame
Added as the 9th major allergen under the FASTER Act (effective January 1, 2023). Sesame seeds and sesame oil must now be declared.
Accepted Allergen Declaration Formats
Format 1 โ€” Parenthetical in Ingredient List
Ingredients: Enriched flour (wheat), butter (milk), coconut flakes (tree nut), eggs, sugar, vanilla extract.
The allergen is identified in parentheses immediately following the ingredient name. Required when the ingredient name alone does not make the allergen obvious.
Format 2 โ€” Separate "Contains" Statement
Ingredients: Enriched flour, butter, coconut flakes, eggs, sugar, vanilla extract.

Contains: Wheat, milk, tree nuts (coconut), eggs.
A bold "Contains:" statement lists all allergens separately, immediately after the ingredient list. Clear, easy for consumers to scan. Most home food sellers find this the simpler format.

Measuring & Declaring Net Quantity

Net quantity declaration is both a labeling requirement and a consumer protection issue. The declared weight or volume must be accurate โ€” consistently under-filling is a regulatory violation; consistently over-filling wastes product and money.

โš–๏ธ
Solid & Semi-Solid Products
Declare in ounces avoirdupois (oz) and grams (g). Use a kitchen scale accurate to at least 1 gram. Weigh net contents only โ€” not the jar, lid, or wrapper. Tare (zero) the scale with the empty container before filling.

Examples: Net Wt 4 oz (113 g) ยท Net Wt 8 oz (227 g) ยท Net Wt 12 oz (340 g)

For very small products under 1 ounce, you may declare in grams only: Net Wt 28 g
๐Ÿฅค
Liquid Products
Declare in fluid ounces (fl oz) and milliliters (mL). Use a calibrated measuring cup or graduated cylinder. Declare the volume of liquid product placed in the container โ€” not the container capacity.

Examples: Net 4 fl oz (118 mL) ยท Net 8 fl oz (237 mL) ยท Net 16 fl oz (473 mL)

For syrups and concentrates, declare the net volume of concentrate, not the diluted volume.
๐Ÿ“
Placement on Label
The net quantity statement must appear on the principal display panel (front face of the package) in the lower 30% of that panel. It must be easily legible and in a font size at least 1/16 inch in height for packages with a principal display area of 5 square inches or less. Larger packages require progressively larger type.

Do not bury net weight in the ingredient list or on the back panel โ€” it must be on the front, in the lower portion.
๐ŸŒก๏ธ
Pacific Climate Considerations
American Samoa's humidity can cause hygroscopic (moisture-absorbing) products like Koko Samoa powder, spice mixes, and dried fruits to gain weight through moisture absorption after packaging. This means a product sealed at the declared net weight may be heavier when opened โ€” which is acceptable. However, packaging designed to prevent moisture ingress is both a quality control and labeling accuracy issue. Use moisture-barrier packaging for dry products.

Font Size, Placement & Format Rules

These technical requirements ensure labels are legible and consistently formatted. They are drawn from FDA labeling regulations (21 CFR Part 101) applicable to American Samoa as a U.S. territory.

Requirement Rule American Samoa Note
Label language English required. Additional languages (Samoan) permitted but do not replace English requirement Including Samoan text alongside English is culturally appropriate and encouraged for local market appeal โ€” but all required elements must also appear in English
Principal display panel The front face of the package most likely seen at point of purchase. Must show product name and net quantity For jars, this is typically the front label. For bags, the largest face. For boxes, the front panel.
Information panel The label panel immediately to the right of the principal display panel when facing the product. Contains ingredient list, allergens, name & address For round jars, any side panel adjacent to the front label qualifies. Many small producers put all required info on a single back label โ€” this is acceptable if all elements are present
Net quantity font size Minimum 1/16 inch (1.6mm) for packages โ‰ค5 sq in PDP. 3/16 inch for 5โ€“25 sq in. 1/4 inch for 25โ€“100 sq in Most home food product labels fall in the 5โ€“25 sq in range โ€” use at least 3/16 inch (about 14pt) type for net quantity
Ingredient list font size Minimum 1/16 inch (about 6pt) on packages with a total label area of 12 sq in or less. 1/8 inch for larger packages Do not go below 6pt โ€” it becomes unreadable and legally non-compliant. Aim for 8โ€“9pt minimum for readability in bright Pacific sunlight at a market stall
Allergen declaration type Must be set in type of the same size and style as the ingredient list, or in bold type to draw attention Bold "Contains:" statements are strongly recommended โ€” they stand out clearly and reduce the risk a consumer misses the allergen disclosure
Date format No mandated format โ€” use any clear date format. Avoid ambiguous formats (04/05/26 could be April 5 or May 4) Recommend: day-month-year format common in Pacific territories: 05 APR 2026 or April 5, 2026
Nutrition Facts panel Required for most packaged foods. Small business exemption applies if: fewer than 100 FTEs AND fewer than 100,000 units sold per year Most American Samoa home food sellers qualify for the small business exemption (21 CFR ยง 101.9(j)(1)). If you claim the exemption, document your annual unit production. As your business grows, reassess annually.
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