Massachusetts · Label Requirements

Label Requirements in Massachusetts

Every element required on every package you sell — from the product name down to allergen declarations — plus what Massachusetts does and doesn't require, with real examples for each field.

Labels Are Mandatory in Massachusetts

Massachusetts requires all cottage food products to be prepackaged with a complete ingredient label before being offered for sale. You cannot sell unwrapped baked goods from a basket without labeling — if the product is packaged, it needs a full label. If it's displayed in bulk (like cookies in a bin), the bulk container must carry the required label information. There is no labeling waiver for small sellers or occasional sellers.

Massachusetts labeling requirements draw from two sources: Massachusetts state law (105 CMR 590 and 105 CMR 520) and federal FDA labeling regulations (21 CFR Part 101). Both apply to your products. The good news is that most of what Massachusetts requires is identical to federal requirements, so complying with one generally means complying with both.

There is no state pre-approval process for labels. You are responsible for ensuring your labels comply — the DPH does not review or approve individual product labels before you go to market. Your local Board of Health inspector may review a sample label as part of your permit application, but this is a check for completeness, not an official approval. Get it right from the start.

No laboratory analysis required. Massachusetts does not require you to have your products analyzed by a food laboratory to generate an ingredient list. You must list all ingredients accurately and in the correct order — but you can do this yourself from your standardized recipe. What you do need a lab for is a Nutrition Facts panel — but most cottage food sellers are exempt from that requirement (see item 8 below).

Everything That Must Appear on Your Label

1
Common or Usual Name of the Product Required
The label must state what the product actually is — its common name. Use the name a consumer would recognize. "Chocolate Chip Cookies," "Strawberry Jam," "Blueberry Muffins." Fancy marketing names alone are not sufficient — the common name must appear.
✓ Good: "Bay State Bakehouse Chocolate Chip Cookies"
✗ Not enough: "Bay State Bites" with no indication it's a cookie
2
All Ingredients Listed in Descending Order by Weight Required
Every ingredient must be listed from heaviest (by weight) to lightest. Sub-ingredients must be fully expanded — you cannot list "flour" if you're using a pre-made flour blend; you must list the flour's components. Similarly, if you use "soy sauce," you must list it as "soy sauce (wheat, soybeans, salt, water)" — the parenthetical sub-ingredients are mandatory.
✓ Correct: "Ingredients: enriched flour (wheat flour, niacin, iron, thiamine mononitrate, riboflavin, folic acid), sugar, butter (cream, salt), chocolate chips (sugar, chocolate liquor, cocoa butter, vanilla extract, soy lecithin), eggs, vanilla extract, baking soda, salt"

✗ Not acceptable: "Ingredients: flour, sugar, butter, chocolate chips, eggs, vanilla, baking soda, salt"
3
Net Weight (Quantity of Contents) Required
The net weight of the product must appear on the label. For products weighing one pound or more, Massachusetts requires a dual declaration — both US customary and metric units. Net weight appears on the lower 30% of the principal display panel.
Under 1 lb: "Net Wt. 8 oz (227g)"
1 lb or more: "Net Wt. 1 pound 4 oz (567g)" — both units required
Count items: "6 cookies" is acceptable for items sold by count
4
Name and Address of the Cottage Food Operation Required
Your legal name (or business name if you have a registered DBA) and your complete home address must appear on every label. This is the address of the residential kitchen where the product was made — your home. Massachusetts requires this so consumers can identify and contact the producer. There is currently no alternative to listing your home address (a voluntary DPH registry with anonymous ID numbers was proposed in S.2761 but was not enacted).
✓ Example: "Produced by: Bay State Bakehouse · Jane Smith · 42 Maple Street, Northampton, MA 01060"
5
Allergen Information — All Major Allergens Required
Federal law (FALCPA and FASTER Act) requires clear declaration of the nine major food allergens. Massachusetts adopts these requirements. Allergens can be declared in the ingredient list (parenthetically) or in a separate "Contains" statement immediately after the ingredient list. Either method is acceptable; using both provides the clearest consumer communication.
6
Storage Instructions (if perishable) Required if applicable
If your product requires refrigeration or freezing after purchase, you must state this clearly: "Keep Refrigerated" or "Keep Frozen." For cottage food products — which are all non-TCS and shelf-stable — this typically does not apply. However, some products benefit from refrigeration for quality (not safety) reasons. If you include any storage guidance voluntarily, make sure it accurately reflects the product's requirements.
Most cottage food sellers do not need this field. A summer butter-frosted cake that genuinely holds at room temperature does not need a refrigeration notice.
7
Open Dating / Use-By Date (if perishable) Required if applicable
For any perishable or semi-perishable food, a use-by date or sell-by date must appear. Once an open-date is placed on a product, it may not be altered. For shelf-stable non-TCS cottage food products, open dating is not strictly required — but including a "Best By" date is good practice and builds consumer confidence.
✓ Good practice: "Best by: [date]" printed or hand-stamped on packaging
✗ Never: Changing or overwriting a date already placed on a package
8
Nutrition Facts Panel Conditional — most sellers exempt
A full Nutrition Facts panel is only required if you make any nutrient content claim, health claim, or other nutritional statement on your label or packaging. Examples that trigger the requirement: "low sugar," "high fiber," "good source of protein," "gluten-free," "only 150 calories per serving." If you make none of these claims, you are almost certainly exempt under the FDA small business exemption (businesses with annual food sales under $50,000 are automatically exempt; businesses under $500,000 in food sales with total revenue under $1 million may also qualify).
Safe: "Homemade Chocolate Chip Cookies — rich, buttery, and full of chips" — no nutrient claim, no Nutrition Facts required.
Triggers requirement: "Only 120 calories!" or "Made with whole grain flour — a good source of fiber"

What a Compliant Label Looks Like

Blueberry Lemon Pound Cake
Homemade in small batches · Massachusetts

Net Weight
1 lb 2 oz (510g)

Ingredients
Enriched flour (wheat flour, niacin, reduced iron, thiamine mononitrate, riboflavin, folic acid), sugar, butter (cream, salt), eggs, fresh blueberries, lemon zest, lemon juice, sour cream (cultured cream), baking powder (sodium acid pyrophosphate, sodium bicarbonate, corn starch, monocalcium phosphate), vanilla extract (water, alcohol, vanilla bean extractives), salt

Allergens
Contains: Wheat, Eggs, Milk, Soy

Produced By
Bay State Bakehouse · Jane Smith
42 Maple Street · Northampton, MA 01060
This product was made in a residential kitchen. This product may contain additional allergens not listed above.
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Unpackaged products at point of sale: If you sell unwrapped items (say, individual cookies displayed on a table at a farmers market), Massachusetts requires a placard posted at the sales location stating that the food is prepared in a kitchen not subject to regulation and inspection by the Board of Health. The exact wording should follow your local Board of Health's guidance. Additionally, your name, address, and ingredient information must be available on request.
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Online sales require label info on the listing page. If you sell on Instagram, Facebook, Etsy, your own website, or any online platform, your product listing must display all the same information that would appear on a physical label — product name, ingredients, allergens, net weight, and your name and address. This is a Massachusetts-specific requirement for online cottage food sales.

The Nine Major Allergens

Federal law (updated by the FASTER Act of 2021) requires clear declaration of nine major food allergens. Massachusetts follows these federal requirements. Every allergen present in your product — even in trace amounts through sub-ingredients — must be declared.

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Wheat
Includes all wheat varieties; barley and rye are not automatically included
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Milk
Dairy in any form — butter, cream, cheese, yogurt, whey, casein
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Eggs
Whole eggs, egg whites, egg yolks, albumin, globulin, ovomucin
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Peanuts
Peanut oil (unrefined), peanut flour, peanut butter
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Soybeans
Soy lecithin (even as an emulsifier), soy flour, tofu, miso
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Tree Nuts
Almonds, cashews, walnuts, pecans, pistachios, hazelnuts — each must be named individually
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Fish
Cod, salmon, tuna, tilapia — each species must be named individually
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Shellfish
Shrimp, crab, lobster, crayfish — each crustacean shellfish species must be named
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Sesame
Added in 2023 (FASTER Act) — sesame seeds, tahini, sesame oil
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Watch for hidden allergens in sub-ingredients. Soy lecithin is in most chocolate chips — that's a soy allergen. Many "enriched flours" contain wheat. Butter is a milk product. Baking powder often contains corn starch (not a major allergen, but note it). Vanilla extract is made with alcohol. Read every ingredient label on every item you use and trace allergens through to your finished product. When in doubt, declare it.

How to Format the "Contains" Statement

Allergens can be declared two ways — or both:

Method 1 — In the ingredient list (parenthetical):
"…chocolate chips (contains milk, soy), flour (contains wheat)…"

Method 2 — Separate "Contains" statement:
"Contains: Wheat, Milk, Eggs, Soy, Tree Nuts (Walnuts)"

Best practice — both: Declare in ingredients AND add a "Contains" statement. This provides the clearest allergen communication for consumers and is what most professional food brands use.

Net Weight & Measurement Requirements

Product Weight / Type What's Required Example
Under 1 oz / 28g Single unit declaration sufficient Net Wt. 0.8 oz (23g)
1 oz to under 1 lb Weight in oz + grams (dual declaration) Net Wt. 8 oz (227g)
Exactly 1 lb Dual declaration required — lb and oz + grams Net Wt. 1 lb (16 oz / 454g)
Over 1 lb Full dual declaration — lb + oz AND grams Net Wt. 1 lb 4 oz (567g)
Sold by count (e.g., cookies) Count plus weight is best practice 12 cookies · Net Wt. 10 oz (283g)
Sold by liquid volume (if applicable) Fluid ounces + milliliters Net Contents: 8 fl oz (237 mL)
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Where on the label: Net weight must appear in the bottom 30% of the principal display panel (the main front face of the package). It should be in a type size proportional to the label area — for packages with a PDP of 5 square inches or less, at minimum 1/16 inch type. For most cottage food packages, just make sure it's clearly readable and in the lower portion of the front label.

Label Elements NOT Required for Most Sellers

To help you avoid over-engineering your labels, here's what Massachusetts cottage food sellers generally do not need — unless specific conditions apply.

Nutrition Facts Panel — Not required unless you make a nutrient content claim ("low sugar," "high protein," etc.). Most cottage food sellers are fully exempt.
Lab-Verified Ingredient List — Massachusetts does not require laboratory analysis. List your ingredients from your own recipe, in descending weight order.
UPC Barcode — Not required for direct-to-consumer sales. Only needed if wholesaling to retail stores (which requires a separate license anyway).
State Pre-Approval Stamp — Massachusetts does not have a label approval process. No sticker, stamp, or official seal is required from the DPH or your Board of Health.
Specific Font Size Minimum — 105 CMR 590 does not specify exact minimum font sizes for cottage food labels (federal rules apply for specific elements like net weight, but there's no general body-text minimum).
Country of Origin — Not required for cottage food products sold directly to consumers within Massachusetts.
Specific Disclaimer Statement — Under current law (105 CMR 590), the proposed S.2761 disclaimer text is NOT yet required for packaged goods. A point-of-sale placard is required for unpackaged display items. Confirm current requirements with your Board of Health.
Certified Organic Claims — "Organic" labeling requires USDA NOP certification regardless of state. Don't use the word without certification. "Made with natural ingredients" is fine; "organic" requires certification.

Labeling for Online Sales & Phone Orders

Online listings must carry full label information

Massachusetts is one of the few states that explicitly addresses online sales in its cottage food framework. When you sell products online — through your own website, Etsy, Instagram DMs, Facebook Marketplace, or any other internet platform — the product listing page must include all information that would appear on a physical label. This means: product name, full ingredient list (with sub-ingredients), net weight, your name and business address, and all allergen declarations.

This requirement protects consumers who may have food allergies and are purchasing without seeing the physical product. A beautiful product photo with a catchy description is not enough — the allergen and ingredient information must be plainly visible on the listing itself, not buried in fine print or a separate linked document.

For phone or mail orders where a physical label is not shown before purchase, Massachusetts requires you to verbally disclose to the consumer that the product was produced in a residential kitchen exempt from state licensing and inspection requirements, and that it may contain allergens. This disclosure should happen before the transaction is completed.


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