US Nutrition Facts Label: What Imports Must Change

What the FDA panel requires, who can skip it, and what happens at the port when it is wrong

The short answer: a US nutrition facts panel is not a translation job. It is a new calculation under FDA rules. The serving size, the required nutrients and the reference values behind every percentage are all set in US regulations.

Our FDA labeling requirements post covers the whole package: product name, origin, allergens. This post goes one level down, into the panel itself.

1. The nutrition facts panel rules apply to imported food

The Nutrition Facts panel is the boxed table of serving size, calories and nutrients. Its format is set in 21 CFR 101.9.

Imports follow the same rules. Asked whether imported foods must meet the updated requirements, FDA answers: "Yes, foods imported to the United States will need to meet the final requirements."

The compliance dates have passed. Manufacturers with $10 million or more in annual sales had to update by January 1, 2020. Those with less than $10 million in annual food sales had until January 1, 2021 (FDA).

Foods that require a panel must use the current US format. Some products qualify for an exemption.

2. Serving size comes from FDA reference amounts, not from the brand

Many brands treat serving size as a marketing choice. In the US it starts from a fixed number: the Reference Amount Customarily Consumed (RACC), the amount people usually eat at one time, set by food category in 21 CFR 101.12.

A few lines from that table:

Chips, pretzels, popcorn and other snacks: 30 g
Cookies: 30 g
Carbonated and noncarbonated beverages: 360 mL (12 fl oz)

Package size adds two rules (FDA):

Packages between one and two servings are labeled as one serving. FDA's examples are a 20-ounce soda and a 15-ounce can of soup.
Some products need a dual-column label that shows calories and nutrients both per serving and per package or unit.

For example, a snack bag sold abroad as "several servings" may need a different serving size once you apply the US reference amount and the package rules.

Change the serving size and every number below it changes too.

3. Added sugars get their own line under Total Sugars

Added sugars is a line that Korea's nine mandatory items do not include. These are sugars added during processing. FDA requires them "in grams and as percent Daily Value" (FDA).

The format is fixed. Per 21 CFR 101.9, added sugars are indented under Total Sugars and read "Includes X g Added Sugars."

There is one carve-out. In its Q&A, FDA says packages of single-ingredient sugars do not need to declare the grams of added sugars. They still show the %DV.

If you only carry over a total sugars figure, the added sugars line is missing.

4. Vitamin D, calcium, iron and potassium: actual amount plus %DV

The updated panel changed the required vitamins and minerals (FDA):

Vitamin D and potassium are required.
Vitamins A and C are no longer required. You may list them voluntarily.
For vitamin D, calcium, iron and potassium, you declare the actual amount (mcg or mg) as well as the %DV.

Percent Daily Value (%DV) shows how much of a daily reference value one serving provides. The reference values for adults and children 4 years and older are in 21 CFR 101.9:

Vitamin D: 20 mcg
Calcium: 1,300 mg
Iron: 18 mg
Potassium: 4,700 mg

The footnote under the panel is standard text too. FDA's version explains what %DV means and states that 2,000 calories a day is used for general nutrition advice.

A %DV copied from another country's label is not a US %DV. Recalculate it against these values.

5. Korean nutrition label vs the US panel

Many of our readers start from a Korean label, so here is how the two compare. Korea's government health portal (KDCA) lists nine mandatory items: calories, carbohydrates, sugars, protein, fat, saturated fat, trans fat, cholesterol and sodium. The same page says mandatory labeling extends to most processed foods from 2026, from 182 to 259 product types.

Item	Korean nutrition label	US Nutrition Facts panel
Mandatory nutrients	9: calories, carbohydrates, sugars, protein, fat, saturated fat, trans fat, cholesterol, sodium	Also added sugars, vitamin D, calcium, iron and potassium, which are not in Korea's nine
Added sugars	Not among the 9 mandatory items	"Includes X g Added Sugars" under Total Sugars, grams and %DV
Vitamins and minerals	Not among the 9 mandatory items	Vitamin D, calcium, iron, potassium: actual amount and %DV
Serving size basis	Korean rules	21 CFR 101.12 reference amounts (snacks 30 g, beverages 360 mL)
Scope	Extends from 182 to 259 product types from 2026	Imports included; small low-volume products can be exempt
Source	KDCA	FDA, 21 CFR 101.9, 21 CFR 101.12

A Korean label is a starting point. The lines it lacks still have to be filled in.

6. The low-volume exemption needs all three conditions

Small products can skip the panel, but the bar is narrow:

Size: the company employs fewer than an average of 100 full-time equivalent employees, and fewer than 100,000 units of the product are sold, or expected to be sold, in the US (21 U.S.C. 343(q)(5)(E)).
Notice: the company generally files an annual notice with FDA. Some qualifying non-importers do not need to file (FDA).
No nutrition messaging: the labels, labeling and advertising "do not provide nutrition information or make a nutrient content or health claim" (21 CFR 101.9(j)(18)).

The third condition is the easiest to miss. For example, "low sugar" on the pack or a nutrition table on your Amazon detail page ends the exemption. Filing details and forms are on FDA's Small Business Nutrition Labeling Exemption page.

Being small is not enough. Check the notice rules and avoid nutrition claims.

7. What happens at import when the panel is wrong

Food is misbranded if "its labeling is false or misleading in any particular" (21 U.S.C. 343(a)). FDA may detain it and allow a request to relabel it. Refusal can follow (FDA):

Refusal code: FDA's code 708FALSE covers products "subject to refusal of admission and administrative destruction pursuant to section 801(a)(3) of the FD&C Act" because the labeling is false and misleading (FDA import refusal codes).
90 days: a refused shipment must be destroyed or exported under CBP and FDA supervision within 90 days (FDA Import Refusals).
10 business days: the same page lists, as a refusal reason, no response to the FDA Notice of Detention and Hearing within ten business days.

The paperwork side, facility registration and FSVP, is in our FSVP post, and the arrival filing is in our Prior Notice post. Clean paperwork does not save a shipment with a bad panel.

A panel error can delay a shipment or lead to refusal.

8. Front-of-package labeling is proposed, not final

FDA proposed a front-of-package nutrition labeling rule in 2025. It is not final. FDA lists the final rule among its Foods Program regulations under development.

Get the Nutrition Facts panel right now. Add front-of-package changes when a final rule exists.

Four checks before you print

1. Does the serving size follow the 21 CFR 101.12 reference amount and the package-size rules?

2. Is there an "Includes X g Added Sugars" line under Total Sugars?

3. Do vitamin D, calcium, iron and potassium show the actual amount and a %DV based on US Daily Values?

4. If you claim an exemption, does it require a notice, and are the pack and ads free of nutrition claims?

Wrap-up

A US nutrition facts panel is rebuilt, not translated. Serving size, added sugars and %DV all follow US rules, and FDA checks the result at the border.

LinkONE handles US customs clearance, FDA compliance, Nutrition Facts creation and English labeling for Korean brands from its Fullerton, California warehouse.

Frequently Asked Questions

Does every imported food need a Nutrition Facts panel?

Most packaged food does. Some low-volume products qualify for an exemption, generally with an annual FDA notice and no nutrition claims. FDA also lists exceptions to the notice requirement (FDA guide).

Can I use my Korean nutrition label?

No. The US panel requires added sugars, vitamin D, calcium, iron and potassium, which are not among Korea's nine mandatory items, and its %DV uses US reference values (FDA, KDCA).

How are added sugars shown on the label?

Indented under Total Sugars as "Includes X g Added Sugars," with a %DV (21 CFR 101.9, FDA).

Who sets the serving size?

FDA's reference amounts in 21 CFR 101.12 set the basis. For example, snacks and cookies are 30 g and beverages are 360 mL (21 CFR 101.12).

What happens if the label is wrong?

FDA may detain the shipment and allow a request to relabel it. If FDA refuses it, the shipment must be destroyed or exported under supervision within 90 days (FDA).

Sources

Rules in this post are as of October 2026.

-LinkONE-