What Must Be on Every CFO Label
Under ARM 37.110.504, every product sold under a Cottage Food Operation registration must be packaged and labeled before sale. The label must include all of the following elements on the principal display panel or an attached label sheet.
Required Label Elements — ARM 37.110.504
CFO Registration OnlyName & Address of the Cottage Food Operation
Your full legal name (or your registered trade/business name) plus your complete physical address: street address, city, state, and ZIP code. This is required so consumers and regulators can trace any product back to you.
Product Name
The common or usual name of the product. Should match what's listed in your registration application. Be specific — "Huckleberry Jam" rather than just "Jam," and "Dark Chocolate Almond Brittle" rather than "Candy."
Complete Ingredient List
All ingredients and sub-ingredients listed in descending order by weight (most predominant ingredient first). Sub-ingredients inside compound ingredients must also be listed — for example, if you use a store-bought chocolate chip, list its individual ingredients in parentheses. Ingredient lists are subject to public disclosure; your actual recipe (measurements and process) is proprietary and protected.
All Common Food Allergens
Declare all major food allergens present in your product. The FDA currently recognizes nine major allergens: milk, eggs, fish, shellfish, tree nuts (specify which type), wheat, peanuts, soybeans, and sesame. List them clearly after the ingredient list using the format "Contains: [allergen]" or parenthetically within the ingredient list — e.g., "flour (wheat)."
Net Weight or Net Volume
The quantity of product in the package, expressed in both U.S. customary and metric units. For solid foods, use weight (ounces and grams). For liquids, use fluid ounces and milliliters. Place the net weight statement in the lower 30% of the principal display panel.
Mandatory Home-Kitchen Disclosure Statement
This is the most critical label element. The exact required statement must appear in at least 11-point font, in a color that provides clear contrast to the background, conspicuously placed on the principal label panel. See the full callout below for the exact wording and formatting requirements.
The Exact Required Disclaimer Statement
Montana law specifies the exact wording that must appear on every Cottage Food Operation product label. You must use this language verbatim — you cannot paraphrase or substitute your own wording. The statement must appear as written, in the required font size, in a contrasting color on the principal display panel.
Sample Montana Cottage Food Label
This example shows a compliant label for a jar of huckleberry jam. Each element is numbered and annotated to help you understand what goes where and why.
Made in a kitchen that also handles Tree Nuts.
The 9 Major Food Allergens
Montana requires you to declare all common food allergens on your label. The FDA currently recognizes nine major allergens — these must be clearly identified whenever they are present in your product, either within the ingredient list or in a separate "Contains:" statement immediately following the ingredient list.
Cross-Contact Disclosure — Strongly Recommended
If your home kitchen also handles allergens not present in a specific product — for example, you bake with peanuts regularly but your shortbread cookies don't contain peanuts — consider adding a voluntary cross-contact statement: "Made in a kitchen that also handles Peanuts." This is not legally required under Montana law but is considered best practice and can protect both your customers with allergies and your business from liability.
Net Weight & Measurement Rules
The net weight statement tells buyers exactly how much product is in the package — not including the weight of the container, lid, or wrapping. Montana follows standard FDA net quantity labeling conventions for cottage food products.
Solid & Semi-Solid Foods
Express in weight: ounces (oz) and grams (g), or pounds (lb) and kilograms (kg). Both U.S. and metric must be shown.
Liquid Foods & Beverages
Express in volume: fluid ounces (fl oz) and milliliters (mL), or pints/quarts and liters.
Placement
The net weight statement should appear in the lower 30% of the principal display panel — the main face of the label the buyer sees first.
Cakes & Large Items
Montana allows large cakes and bulk products to use a label sheet — a card placed with the product — instead of an affixed label, as long as required information is provided and the product is protected from contamination.
Special Labeling Cases
🌾 Gluten-Free Claims
You may state "Gluten-Free" on your label if your product contains no gluten-containing ingredients — but you must follow FDA gluten-free labeling standards, which require the product to contain less than 20 parts per million (ppm) of gluten. Your home kitchen cannot be certified as a gluten-free facility. Include a cross-contact disclosure if you use wheat or other gluten-containing ingredients in the same kitchen: "Made in a kitchen that also uses wheat flour." Never use "gluten-free" as a simple claim without confirming your product and process actually meet the FDA threshold.
🍯 Honey Labels
Honey is an approved Cottage Food Operation product. DPHHS specifically recommends that honey sellers add the following voluntary statement to their label: "Honey is not recommended for infants less than twelve (12) months of age." This is not legally required under Montana cottage food rules but is strongly recommended by DPHHS and reflects standard food safety guidance for honey products nationwide.
🎂 Celebration Cakes & Bulk Items
Montana specifically accommodates large celebration cakes (birthday, anniversary, wedding) and bulk items that cannot have a traditional label affixed to the product. These may be sold using a label sheet — a card, tag, or sheet attached to or accompanying the product — as long as all required label information is provided and the product is protected from contamination. The label sheet must still include every required element, including the home-kitchen disclaimer in 11-point font.
🔒 Ingredient Lists Are Public — Recipes Are Private
When you submit your registration application, your ingredient lists are subject to public disclosure under Montana records law. However, your actual recipe — the specific measurements, ratios, and production process — is considered proprietary information and is not subject to public disclosure. Your county sanitarian and DPHHS have access to your full recipe for regulatory purposes but cannot share it publicly. List ingredients on your label as required, but you do not need to include measurements or preparation steps.
🌿 Selling Under MLFCA? Labeling Is Optional — But Still Smart
The Montana Local Food Choice Act explicitly exempts sellers from all labeling requirements. You are not required to put any label on your products when selling under MLFCA. The only requirement is that you inform each buyer the product "has not been licensed, permitted, certified, packaged, labeled, or inspected per any official regulations."
That said, voluntary labeling is strongly recommended even under MLFCA — for your protection and your customers'. A simple label with your name, what's in it, major allergens, and a best-by date gives customers confidence, helps with traceability if a concern arises, and makes your products look more professional at farmers markets. Many MLFCA sellers use labels similar to CFO labels, without the regulatory disclaimer, simply as a matter of good business practice.
Montana Label Creator
Create compliant Montana cottage food labels with the required disclosure statement pre-filled, allergen fields built in, and the correct font size and placement applied automatically. Download as a print-ready file.
Open Label Creator — Free with Account →Label Compliance Checklist
Before printing or submitting your labels with your CFO registration application, confirm every item below is present and correct.