Label Requirements in the Northern Mariana Islands

Good labeling protects your customers, builds trust, and keeps you legally compliant. While the CNMI's cottage food framework via SB 24-31 has not been fully confirmed, labeling requirements are shaped by two consistent sources: the FDA Food Code that CNMI has now adopted, and the federal Fair Packaging and Labeling Act (FPLA) which applies to all U.S. territories. These requirements apply regardless of which permit pathway you use. [VERIFY] any CNMI-specific disclaimer wording directly with CHCC EHDP once SB 24-31's status is confirmed.

Required Label Elements

Every product you sell from your home kitchen in the Northern Mariana Islands must include these elements on its label. All elements must be legible — clear, readable type on a contrasting background. For small labels, use the minimum font sizes described below.

• 1

  Product Name

  The common or usual name of the food. Must clearly identify what the product is. Use the name a reasonable consumer would recognize — "Chamorro Coconut Cookies," "Donni' Såli Hot Sauce," "Ginger Honey Granola."

  Example: "Guyuria — Chamorro Coconut Cookies"
• 2

  Net Weight or Net Volume

  The quantity of product in the package, expressed in both U.S. customary units (oz, fl oz) and metric units (g, mL) for packaged products sold to consumers. Declare the weight of the food only — not the packaging. Place on the lower 30% of the principal display panel.

  Example: "Net Wt 6 oz (170 g)" or "Net 8 fl oz (237 mL)"
• 3

  Ingredients List

  All ingredients listed in descending order by weight — the heaviest ingredient first. Use common names for each ingredient. Sub-ingredients of compound ingredients must be declared in parentheses. Water is an ingredient and must be listed if used in production.

  Example: "Ingredients: Flour, Sugar, Butter, Eggs, Coconut (Dried), Vanilla Extract, Salt"
• 4

  Allergen Declaration

  The nine major allergens recognized by the FDA must be clearly declared. See the allergen section below for the full list and correct declaration formats. This is a federal requirement that applies in all U.S. territories including the CNMI.

  Example: "Contains: Wheat, Eggs, Tree Nuts (Coconut)"
• 5

  Seller Name and Address

  Your full legal name (or business name if registered) and your complete address in the CNMI — island, municipality, and postal code. This allows consumers and regulators to contact you if needed. A P.O. Box is acceptable for the address.

  Example: "Made by Maria Santos · P.O. Box 1234, Saipan, MP 96950"
• 6

  CNMI Home Kitchen Disclaimer

  A statement identifying that the product was made in a home kitchen not inspected by a food safety authority. The exact wording depends on what SB 24-31 specifies once confirmed — see the disclaimer section below for the recommended language. [VERIFY] required wording with CHCC EHDP.

  See disclaimer section below for full wording
• 7

  Best By / Best If Used By Date

  While not universally mandated by federal law for all foods, a best-by date is strongly recommended — and may be required under CNMI's FDA Food Code framework. Given the CNMI's tropical humidity, it is especially important to set conservative shelf-life dates and communicate them clearly to buyers.

  Example: "Best By: 15 Oct 2026"
• 8

  Storage Instructions (if applicable)

  Required if the product needs specific storage conditions to maintain quality or safety. Most shelf-stable cottage food products need only "Store in a cool, dry place." Any product with a refrigeration requirement after opening must state this clearly.

  Example: "Store in a cool, dry place away from direct sunlight."

CNMI Home Kitchen Disclaimer

Most cottage food frameworks in the United States require a specific disclaimer statement on every label, notifying the buyer that the product was made in a home kitchen not subject to commercial food safety inspection. The exact wording for the CNMI must be confirmed with CHCC EHDP once SB 24-31's enacted status is established. Until then, the following language reflects the standard approach used across similar U.S. jurisdictions and the FDA Food Code framework CNMI has adopted — use it as a starting point and update once CNMI-specific wording is confirmed.

Allergen Labeling — The 9 Major Allergens

The FDA's FASTER Act (2023) expanded the major food allergen list to nine. These are federal requirements that apply in all U.S. territories including the CNMI. You must declare any of these allergens present in your product — either in the ingredients list or in a separate "Contains" statement immediately following it.

You have two acceptable formats for declaring allergens:

Option B — the separate "Contains" statement — is generally clearer for consumers and easier to write. Both formats are legally acceptable. Important for CNMI sellers: Coconut is widely used in Chamorro and Pacific Island cooking. Coconut is classified as a tree nut allergen by the FDA. If your product contains coconut — including coconut milk, shredded coconut, or coconut oil — you must declare it.

Net Weight & Measurement Rules

Net weight declarations follow the federal Fair Packaging and Labeling Act (FPLA) and must appear on the lower 30% of the principal display panel (the front face of your label). Dual declaration — both U.S. customary and metric — is required for consumer packaged foods.

Font Size & Placement

The FDA has minimum font size requirements for several label elements. While CNMI-specific minimums must be confirmed with CHCC EHDP, the following federal standards apply across all U.S. territories as a baseline:

Sample Label — What It All Looks Like

Here is how a compliant CNMI home food seller label might look for a batch of guyuria (Chamorro coconut cookies), incorporating all required elements.

Sample only — not legal advice. Verify required disclaimer wording with CHCC EHDP once SB 24-31's status is confirmed.

Practical Labeling Tips for CNMI Sellers

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