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The FDA is proposing one of the most consequential labeling updates in decades. 

A mandatory Front-of-Package (FOP) “Nutrition Info” box would move essential nutrition information from the back or side panels to the front of food packaging. 

While nutrition labeling itself is not new, placing interpretive information directly on the front marks a significant shift in how consumers will evaluate product health. 

🧾 What Is the Proposed FOP Nutrition Label?

The new “Nutrition Info” box is designed to appear on the front of most packaged foods. It focuses on three nutrients that Americans are encouraged to limit: saturated fat, sodium, and added sugars.

This format is intended to provide simplified, at-a-glance guidance that supports healthy decision-making. FDA research found that interpretive FOP labeling improves consumer understanding of nutritional quality. A nationwide study of over 9,200 adults showed that consumers were better able to identify healthier products when using the proposed “Nutrition Info” box. 

📦 Who Will Be Affected?

The new rule will apply to nearly all packaged foods that are currently required to display a Nutrition Facts label. This includes national and private-label brands, as well as co-manufactured goods.

There are some exceptions:

Products and Categories Exempt from the FOP Rule

1. Products for Children Under 4 Years Old
   Foods marketed specifically for children under 4 (including infants and toddlers) are excluded. The FDA noted differences in nutritional needs and a lack of standardized % Daily Values for some nutrients in this age group.
   
2. Very Small Packages
   Packages with less than 12 square inches of total surface area available for labeling are exempt from the FOP box requirement entirely.
   
3. Foods Not Required to Bear Nutrition Facts Labels
   Some products are exempt from full Nutrition Facts labeling under existing rules, such as:
   
   • Fresh produce and seafood
     
   • Certain coffee and tea products
     
   • Some ready-to-eat foods sold in small retail operations (e.g., bakeries or delis)
     

📅 When Will This Take Effect?

If finalized, the rule will be implemented with a compliance timeline based on company size:

• Three years after the final rule for businesses with more than $10 million in annual food sales
• Four years for smaller businesses
  

✅ Placement and Size Requirements

• The FOP Nutrition Info box must appear in the upper third of the principal display panel (PDP).
• The minimum type size is 8 point for all text in the box. Additionally, the type size must be no smaller than the size used in the net quantity of contents declaration on the same PDP.

🎨 What This Means for Brands

Although this rule may be a few years from being implemented, there are a few things to start planning for now. 

• If you have a major package redesign coming up, allocate space on the front panel for the Nutrition Info box to be easily added in the future.
  
• Although reformulation is not required, some companies may choose to make changes in order to maintain positive consumer perception. If you are reformulating due to tariffs or other reasons, perhaps this is a good time to also re-evaluate the levels of saturated fat, sodium, or added sugar.

You can provide comments, an objection, or propose an alternate solution. The public comment period has been extended through July 15, 2025. Feedback can be submitted through Regulations.gov.

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References:
https://www.fda.gov/media/185015/download?attachment
https://www.fda.gov/media/185014/download?attachment
https://www.fda.gov/media/175629/download?attachment
https://www.federalregister.gov/documents/2025/01/16/2025-00778/food-labeling-front-of-package-nutrition-information
https://www.flickr.com/photos/fdaphotos/albums/72177720323029865/