๐Ÿท๏ธ Pennsylvania ยท Label Requirements

Label Requirements in Pennsylvania

Every product you sell as a Pennsylvania LFE seller must be properly labeled before it leaves your kitchen. Your PDA inspector reviews labels during your home inspection โ€” and buyers, markets, and wholesalers all expect compliant packaging. Here's every required field.

โœ… Pennsylvania does not have a single, word-for-word required disclaimer statement like some other states' cottage food programs. Instead, LFE sellers follow the standard food labeling requirements under Pennsylvania's Food Safety Act and applicable federal FDA labeling rules. The core requirements are: product name, business name and address, ingredients in descending order by weight, major allergens, and net quantity. Some products have additional requirements โ€” particularly acidified foods and those shipped interstate.

โš ๏ธ Labels are reviewed at inspection and on an ongoing basis. Your draft product labels must be included in your LFE application packet. During your home inspection, the PDA food sanitarian will review your labels and discuss any corrections needed. Labels that don't comply with state and federal requirements must be corrected before you begin selling.

What Must Appear on Every Pennsylvania LFE Label

These six fields are required on every product label for Pennsylvania Limited Food Establishment sellers. No exceptions โ€” all must be present and legible before the product is sold.

1
Product Name
The common or usual name of the food โ€” what it actually is, not just your brand name. If the product is an unusual or invented food, include a description that accurately describes the food to the buyer.
Examples: "Strawberry Jam" ยท "Hot Sauce" ยท "Lemon Pound Cake" ยท "Mixed Berry Preserves"
2
Business Name
The name of your food business โ€” your legal business name or your registered DBA (Doing Business As) name. This is the name that appears on your LFE registration.
Example: "Blue Ridge Preserves" ยท "Maria's Kitchen" ยท "Stone Creek Sauce Co."
3
Business Address
Your complete home or business address โ€” street address, city, state, and ZIP code. This must be a real, physical address where your food is produced. A P.O. Box alone is not sufficient. If you are concerned about privacy, consider forming an LLC and using your registered agent's address, or a UPS Store suite address โ€” but confirm with PDA whether a non-home address is acceptable for your registration. [VERIFY with PDA]
Example: "Blue Ridge Preserves ยท 123 Maple Lane ยท Lancaster, PA 17601"
4
Ingredients List
All ingredients must be listed in descending order by weight โ€” the most prominent ingredient first. Use the common or usual name for each ingredient. Sub-ingredients within a compound ingredient (like enriched flour) must be listed in parentheses.

No shortcuts: "natural flavors" must be listed if present, water must be listed, and even incidental additives like stabilizers or preservatives must appear.
Example: "Ingredients: strawberries, sugar, lemon juice, pectin"
5
Major Allergen Declaration
If your product contains โ€” or is made in a kitchen that also uses โ€” any of the 9 major food allergens, they must be clearly declared on the label. Pennsylvania follows federal FDA allergen labeling requirements under the Food Allergen Labeling and Consumer Protection Act (FALCPA) and the FASTER Act (2023).

Allergens may be declared in one of two ways: (1) within the ingredient list using the common name in parentheses โ€” e.g., "enriched flour (wheat)" โ€” or (2) in a separate "Contains:" statement immediately after the ingredient list โ€” e.g., "Contains: wheat, milk, eggs."
Example: "Contains: milk, eggs, wheat, soy" or "Contains: tree nuts (almonds)"
6
Net Quantity / Net Weight
The amount of food in the package, expressed in both US customary and metric units for most products. Solid or semi-solid foods use weight (oz/g or lb/kg). Liquid products use volume (fl oz/mL). Mixed products use weight unless the product is naturally sold by count.

Net weight must appear in the bottom third of the principal display panel โ€” the front face of the label.
Examples: "NET WT 8 oz (227 g)" ยท "NET 12 fl oz (355 mL)" ยท "NET WT 1 lb 4 oz (567 g)"

โ„น๏ธ Legibility matters. Pennsylvania's LFE regulations require labels to be legible โ€” readable by the consumer under normal purchase and use conditions. There is no specific minimum font size mandated in the LFE program for most fields, but federal FDA rules require ingredient and allergen text to be at least 1/16 inch (1.6mm) in height for most products. When in doubt, err larger โ€” your inspector will flag illegible text.

What a Compliant Pennsylvania LFE Label Looks Like

This sample label shows all required elements for a typical Pennsylvania LFE product โ€” a strawberry jam. Every numbered field corresponds to a required element.

โ‘  Product Name
Strawberry Jam
โ‘ก Business Name    โ‘ข Business Address
Blue Ridge Preserves
123 Maple Lane ยท Lancaster, PA 17601
Strawberries, sugar, lemon juice, pectin.
Contains: No major allergens.
If allergens were present: "Contains: tree nuts (pecans)"
Best by: 12 months from production ยท Refrigerate after opening
NET WT 8 oz (227 g)

๐Ÿ“‹ Note on the "not inspected" disclaimer: Some third-party sources suggest Pennsylvania LFE labels should include a disclaimer stating the food was "prepared in a kitchen not subject to state inspection." This language is commonly found in other states' cottage food programs. Pennsylvania's LFE program requires a home inspection before registration, so this disclaimer does not accurately apply to registered LFE sellers. Your PDA food sanitarian will advise you on any specific label language they require during your inspection. [VERIFY with PDA at RA-FoodSafety@pa.gov whether any kitchen disclaimer is required for LFE labels]

The 9 Major Food Allergens

Under the federal Food Allergen Labeling and Consumer Protection Act (FALCPA) and the FASTER Act (effective January 1, 2023), there are 9 major food allergens that must be declared on food labels whenever they are present as an ingredient or in a sub-ingredient. Pennsylvania LFE sellers follow these federal rules.

These allergens must be declared every time they appear โ€” even in small amounts from a flavoring, spice blend, or processing aid. There is no threshold below which declaration is optional.

๐ŸŒพ
Wheat
Includes all wheat varieties
๐Ÿฅ›
Milk
Includes dairy in all forms
๐Ÿฅš
Eggs
Includes egg whites and yolks
๐Ÿฅœ
Peanuts
Distinct from tree nuts
๐ŸŒฐ
Tree Nuts
Almonds, cashews, pecans, walnuts, etc.
๐ŸŸ
Fish
Must name species (e.g., "salmon")
๐Ÿฆ
Shellfish
Must name species (e.g., "shrimp")
๐Ÿซ˜
Soy
Includes soy lecithin and derivatives
๐ŸŒฟ
Sesame
Added by FASTER Act โ€” effective Jan 1, 2023

โš ๏ธ Shared kitchen / cross-contact advisory statements: If you produce multiple products in the same kitchen and some contain allergens that others don't, you may wish to add a voluntary advisory statement such as "Made in a facility that also processes tree nuts." These advisory statements are voluntary for home food sellers โ€” they are not required by Pennsylvania's LFE program โ€” but they are strongly recommended as a customer safety and liability protection measure. Never include an advisory statement that is false or misleading.

Net Weight & Measurement Rules

Net quantity (net weight or net volume) is one of the most frequently mis-labeled elements on home food products. Here's how to get it right for every product type.

Product Type Measurement Used Format Required Example
Solid food (cookies, candy, granola) Weight US + metric NET WT 6 oz (170 g)
Liquid / pourable (hot sauce, syrup, vinegar) Volume US + metric NET 5 fl oz (148 mL)
Semi-solid / viscous (jam, salsa, nut butter) Weight US + metric NET WT 8 oz (227 g)
Mixed solid/liquid (pickles in brine) Weight or volume (weight preferred) US + metric NET WT 12 oz (340 g)
Dry mixes & spice blends Weight US + metric NET WT 2 oz (57 g)
Individual baked goods sold by unit Count (if sold individually) Count only 1 Loaf ยท 12 Cookies ยท 1 Pie
Beverage (kombucha, juice, switchel) Volume US + metric NET 16 fl oz (473 mL)

โ„น๏ธ Where net weight goes on the label: Net weight must appear in the lower 30% (bottom third) of the principal display panel โ€” the front face of the package or the most prominent face when it's displayed for sale. It must be in a type size that's easy to read. For packages with 5 sq inches or less of display area, net weight can appear anywhere on the label.

pH Batch Log for Acidified Products

If you produce jams, jellies, salsa, hot sauce, pickles, chutneys, fermented foods, kombucha, or any other acidified product, Pennsylvania requires you to maintain a production batch log in addition to standard labeling. This log is not printed on your label โ€” it is a production record kept by you for PDA inspection and review.

๐Ÿ“‹ Monitoring frequency: If your acidified product has a final pH at or above 4.0, check and log the pH of every batch. If consistently below 4.0, check and log at least four times per year. If your product tests above pH 4.4, stop production and contact PDA โ€” Process Authority approval is required before you can produce or sell that product.

Sample Batch Log Format

Your batch log must include at minimum: production date, batch/lot number, product name, pH reading, and any corrective action taken if the pH was out of range.

Production Date Batch # Product pH Reading Corrective Action / Notes
2026-03-01 JAM-001 Strawberry Jam 3.4 None required โ€” pH within acceptable range
2026-03-08 SAL-002 Garden Salsa 3.9 None required โ€” pH within range
2026-03-15 HOT-003 Red Pepper Hot Sauce 4.2 Adjusted with additional vinegar โ€” re-tested at 3.8. Batch released.
2026-03-22 KIM-004 Traditional Kimchi 3.6 None required โ€” natural fermentation pH confirmed

This log is a production record, not a label element. Keep it on file and make it available for PDA inspection. A simple spreadsheet or notebook works โ€” no specific format is mandated beyond the required data fields.

Do You Need a Nutrition Facts Panel?

Full FDA-format Nutrition Facts panels are not required for most small Pennsylvania LFE sellers under normal selling conditions. However, there are specific situations where they become required โ€” and understanding the rules protects you.

โœ… Nutrition Facts NOT required when...
  • โœ“ Your annual food sales are under $50,000
  • โœ“ Your total gross annual sales are under $500,000 [VERIFY current FDA threshold]
  • โœ“ You make no health claims ("low fat," "high fiber," "sugar free," etc.)
  • โœ“ Your product is sold at farmers markets, from home, or through local retail
  • โœ“ You are not shipping to buyers in states that require nutrition panels
โš ๏ธ Nutrition Facts ARE required when...
  • ! You make any health or nutrient content claim on your label ("low sodium," "gluten-free nutrition claim," etc.)
  • ! You ship products interstate via mail order (federal rules apply)
  • ! You sell to retailers or food service accounts who require it
  • ! Your annual food sales exceed FDA small business thresholds [VERIFY]
  • ! Your wholesale buyers or distributors contractually require it

โ„น๏ธ Pro tip for growing sellers: Even if not required, adding a Nutrition Facts panel early signals professionalism and makes it easier to expand into retail stores or online wholesale accounts later. Several free tools can generate FDA-compliant Nutrition Facts panels from your recipes โ€” Penn State Extension's food safety team can point you to approved resources.

Labeling When You Ship Out of State

Pennsylvania's LFE program explicitly allows interstate shipping โ€” a rare permission that opens your business to buyers across the country. However, when you ship to other states, federal labeling rules apply more strictly, and the destination state's cottage food or food labeling rules may also apply to your product. The key additional requirements for interstate shipments:

Nutrition Facts Panel
Required on all shipped products when interstate commerce is involved, unless you qualify for the small business exemption. Review your annual sales against current FDA thresholds.
FDA Facility Registration
Pennsylvania LFE sellers (homes) are specifically exempt from FDA Bioterrorism Act facility registration. You do not need to register with FDA to ship your products.
Destination State Rules
Some states restrict what food products can be shipped in. Confirm that the food category you are shipping is legal in the destination state. This is especially relevant for meat jerky and certain beverages.
Unpasteurized Juice Warning
If shipping unpasteurized juice, the FDA-mandated warning label is required: "WARNING: This product has not been pasteurized and, therefore, may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems."

Common Labeling Mistakes Pennsylvania LFE Sellers Make

These are the most common labeling errors that PDA inspectors flag and that cause labels to be rejected. Review your labels against each one before your inspection.

โœ• Missing net weight on the front panel
Net weight belongs in the bottom third of your principal display panel โ€” the front of the package. A weight printed only on the back or side is non-compliant.
Fix: Add "NET WT X oz (X g)" to the lower front of every label.
โœ• Ingredients not in descending weight order
Listing ingredients alphabetically or randomly โ€” rather than by weight โ€” is a frequent error on homemade food labels. The most prominent ingredient by weight must come first.
Fix: Weigh each ingredient in your recipe and list them heaviest-to-lightest.
โœ• Missing allergen declaration
Any of the 9 major allergens present in any ingredient โ€” even a small amount from a compound ingredient or spice blend โ€” must be declared. "Contains natural flavors" is not sufficient if soy is in those flavors.
Fix: Check every ingredient's sub-ingredients for hidden allergens before printing labels.
โœ• Using only a P.O. Box for address
Your label must include a complete physical address. A P.O. Box alone does not satisfy the address requirement. A P.O. Box may be included additionally, but a street address must also be present.
Fix: Include your street address, city, state, and ZIP. Add P.O. Box separately if desired.
โœ• Making health claims without a Nutrition Facts panel
Terms like "low sugar," "high protein," "keto-friendly," or "gluten-free" are nutrient content or health claims โ€” they trigger the requirement for a full FDA Nutrition Facts panel even for small sellers.
Fix: Either add a compliant Nutrition Facts panel, or remove the health claim language from your label entirely.
โœ• Illegible text โ€” too small to read
Ingredient lists and allergen declarations with 6pt or smaller type are a common complaint from both PDA inspectors and customers. Labels printed on home inkjet printers at very small sizes often fail this test.
Fix: Use at minimum 7โ€“8pt type for ingredient text; 10pt or larger for the product name and business name. Test-print and hold at arm's length to verify readability.
๐Ÿท๏ธ

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