You need to know these FDA requirements when labeling a hot sauce!


If you want to compete with hot sauces on store shelves and online retailers on a global or domestic level, then you need to provide a label that follows the FDA requirements. This is standard for all condiments and hot sauces and you will see similarities just by reading the packaging.

When providing a label for a hot sauce or condiment the Food and Drug Administration (FDA) requires that it must include a product name, the net weight of the product, manufacturing information, and nutritional data. The brand name and bar code are not part of the FDA label requirements.

Although many of the requirements that the Food and Drug Administration have for food products are similar to hot sauce, some nuances are specific to the type of sauce and size of the bottle. There are many versions of a hot sauce that can fall under the title of “hot sauce” so be aware of the type of sauce you have created. This is also important for marketing purposes and pairing food.  The FDA requires the type to be bold and stand out among graphics on the label. If you are producing 5 oz bottles of sauce, which is typical, then there may not be much surface space left for the product name.

Know and understand the type of hot sauce you make

The words “traditional” or “gourmet” do not need to accompany the words “hot sauce” but the more descriptive you are with the product the more understanding your consumers will have. The FDA does require the product name on a label so if your hot sauce is more of a Picante or salsa then that needs to be included.

The consistency will also decide the product name. A thick sauce or paste would be labeled with the word “paste” and not necessarily “hot sauce”., although it is recommended to include the words “pepper”, “hot” or “spicy” in the name of the product if it is descriptive of the sauce.

Consider the size of the bottle during design

Many specialty and sample hot sauces are packaged in 5 oz or 3 oz bottles. This may not give much surface to display the information required. Take this into consideration when designing the Product Display Panel. The information on the PDP will be on the front-facing surface so this will give even less of an area to display information.

Graphics can be a huge part of marketing a new hot sauce product by using amusing artwork and colorful graphics. These can attract attention but also interfere with the label contents or become overbearing against the product name.

What is the Product Display Panel?

Typically, a Product Display Panel (PDP) is on the face of the product that is front-facing and seen by the consumer. The Product Display Panel should be the most prominent display seen by the consumer and this is where specific requirements such as the name of the product and quantity or weight will be displayed.

Considering that a hot sauce bottle is round the front-facing surface would be where the PDP is placed. A portion of this will wrap around the bottle but the name of the product should be front-facing and visible. For a hot sauce, the PDP is often part of the other nutritional data and informational panel.

The name of the product is different from the brand

The name of the product or statement of identity should stand out on the PDP, but this does not include the brand name or logo. Marketing tactics have forced manufacturers to highlight the brand name on the bottle and make it bigger than the statement of identity but the name of the product needs to be visible.

The FDA does not regulate what you call the product but a start-up brand of sauce should have the words “hot sauce” somewhere on the PDP. This statement could be embellished or changed to include the words gourmet, Louisiana style, or other words describing the product such as artisan, Caribbean, or craft.

Hot sauce needs to include the information panel

The information panel will include the name and address of the manufacturer, packaging, or distributor and the nutritional information, ingredient list, and any allergy labeling. The information panel will be directly to the right of the PDP. Although products intended to be sold in retail business should have a bar code the FDA does not require that a hot sauce have one.

Additional information on the information panel will be allergen information and voluntary ingredients like vitamin contents. This side panel does not typically contain any artwork although there may be a minimized logo. This is not an FDA recommendation, but many manufacturers will include it toward the bottom right or left corner.

The importance of type size

The type size should be large, easy to read, and contrast with the background label. Although there is no FDA regulation with the length of the product description, “Tom’s super-hot deluxe road burning tongue scorching hot sauce” may be difficult to display on such a small package.

Hot Sauce Artwork can grab your attention

Hot sauce labels and brand names are becoming more extravagant as unique ingredients and flavors are being introduced. The FDA states that the artwork should not misrepresent the hot sauce. I do not see how a gentleman with his pants down, sitting in a tub with smoke coming out his rear is in any way a misrepresentation of the sauce…click here to see what I am talking about. The FDA does not regulate hot sauce bottle designs which is why the names and artwork are often very extravagant.

Listing the ingredients

Per FDA guidelines the ingredients will be listed in order by weight. This also includes sub-ingredients, ingredients that are part of another product. There are specific requirements for what ingredients need to be included as part of your hot sauce recipe.

The FDA does not require that a percentage of the ingredients be declared on the label. There are specific requirements for juices, which are often part of gourmet hot sauces, but not necessary to be excluded as a percentage.

Weight of the sauce does not include packaging

The FDA also requires the net weight to be printed clearly on the packaging displaying the US customary and the metric measurement. This would include the net weight of the hot sauce and not the packaging associated with it. The weight is also considered part of the label statement and should appear on the PDP, usually toward the bottom of the label.

The net quantity of contents or weight of the product should include all of the ingredients that constitute the end product of hot sauce, but the weight of each ingredient does not need to be listed. However, you should have this information documented somewhere.

Food allergens must be listed on the label

The list of food allergens from the FDA covers about 90% of food allergies and fortunately many are not used in hot sauce recipes. If your hot sauce contains one of the items on the food allergen list thoroughly read section F1 – F16, then it needs to be included on the information panel. It is good practice to label a hot sauce as gluten-free, vegan, zero calories, or allergen-free…if it is.

Hot sauce needs a nutritional label

There is specific information needed on the nutritional label including the order, even though your hot sauce may not include any of the information, it needs to be displayed. Only nutrients that are listed as mandatory or voluntary need to be included. Your hot sauce can be tested for nutritional value at a laboratory. Read How to provide a nutritional label for your hot sauce for some of the details on what is required by the FDA. Also, check out recipal.com for nutritional labeling as low as $19 a recipe.

Most co-packaging companies will provide labeling per the FDA regulations. A co-packing company is a company that will make your hot sauce recipe in large quantities, bottle it, and label it for sale without the need for you to be involved in manufacturing. Most likely they produce their hot sauces and are aware of FDA labeling requirements.

Consider label size during design

There is not a limit to how big or how small a product label can be but generally speaking, the PDP, information panel, and bar code will be one label wrapped around a bottle of hot sauce. The FDA does not have any objections to this, but a 5 oz bottle will not provide much room to display product information.

Where DON’T I need a label?

There are occasions where you do not need a product label on a hot sauce. If you plan on selling outside of retail stores or online shops, then a product label isn’t needed. Farmer’s markets, craft fairs, or your restaurant also would not require labels to the extent that the FDA requires but it is a good communication practice.

What is great about hot sauce is that a woozy bottle makes it instantly recognizable as a hot sauce. If you own an establishment that provides food that pairs well with hot sauce then providing your hot sauce without a label would be fine.

Reasons not to label a hot sauce

The reason NOT to label a hot sauce aside from the reason listed above is that it could be time-consuming and add additional costs. If you have a new product, you are sampling then you may not want to put in the effort to design a label, purchase a nutritional label and a bar code until it has been widely accepted.

Bottle labeling machines

Like a lot of pieces of equipment, there can be varying differences in products to include pricing, automated, manual, and the number of units produced per minute. A start-up hot sauce company would probably want to use inexpensive manually operated machines. Labels can be applied to individual bottles by hand but this increased the possibility that the labels could be off-set.

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