What Does the FDA Require on a Microgreens Label?

A sealed package of cut microgreens needs three things federally: what it is, how much is in it, and who is responsible for it. Everything past that depends on specific facts about your product.

Most of what circulates as "FDA label requirements for microgreens" is a generic packaged food checklist copied onto a bag of greens, and it over-labels. A single ingredient raw agricultural commodity carrying no claim skips the ingredient list and skips the Nutrition Facts panel. Neither of those is a courtesy; both are written into the regulations.

The expensive mistakes run the other direction. A grower adds "high in vitamin K" to the front panel and quietly loses a nutrition labeling exemption. A qualified exempt farm leaves off the address statement the Produce Safety Rule attaches to its packaging. A state weights and measures rule turns out to have been valid all along.

This page is the federal baseline. Your state adds on top of it.

The five federal label elements

Every FDA regulated food in package form works from one short list. What varies is how many items your product triggers.

That placement framework comes from FDA's general labeling guide. Three conditional requirements sit alongside it: a food containing a major allergen must identify the allergen's food source, a label making a nutrient content or health claim must satisfy the claim rules and the nutrition labeling rules, and imported food carries country of origin marking administered by Customs rather than FDA. No source behind this page treats country of origin as a general FDA label element for domestically grown microgreens.

What a plain clamshell actually needs

Use a clear identity such as "Cut radish microgreens" or "Microgreens mix", declare the net weight, and identify the responsible firm by name and address. The product is one raw agricultural food, not a multi ingredient formulated food, so it needs no ingredient list merely to repeat the word "microgreens" back to the buyer.

That changes the moment anything beyond raw microgreens enters the package. Oil, dressing, seasoning, a wash retained as an ingredient, seeds sold alongside the product, a separately added topping: any of those makes it a fabricated food, and every ingredient that must be declared has to be named by its common or usual name and ordered by weight, heaviest first, per 21 CFR 101.4. A "microgreens and toasted sesame" pack is not a single ingredient product.

Where each statement has to sit

The principal display panel is the part of the package most likely to be seen by a buyer at purchase, and any alternate principal display panel has to carry the same mandatory statements as the main one. Identity and net quantity both belong there. The food name runs in lines generally parallel to the base of the package and has to be prominent, per 21 CFR 101.3(a) and (d).

The information panel is normally the panel immediately contiguous to the PDP and to its right as the consumer faces the package; if that panel is unusable or too small, move to the next panel to the right. Business identity, the ingredient list where required, Nutrition Facts where required, and any required allergen statement normally appear together on that panel, in one place, with no intervening non-required matter between them. 21 CFR 101.2(b) requires those Part 101 statements to be on the PDP or the information panel, and 101.2(e) is the provision that forbids breaking the block up with marketing copy. Where space permits, required information may appear on the PDP instead, which is what makes a small single face clamshell workable.

The net quantity declaration, unit by unit

Cut microgreens are declared by weight, never by fluid measure: 21 CFR 101.7(a) puts solids, semisolids, viscous foods, and solid or liquid mixtures on weight. A compliant declaration reads "Net Wt. 2 oz (57 g)".

Section 101.7(b)(1) requires U.S. customary weight units, avoirdupois pounds and ounces. Section 101.7(p) then permits an accurate metric statement as an additional declaration. Read together, the metric figure in parentheses is optional under federal law, not required, though plenty of guides say otherwise. This is a fixed regulatory rule, not an inflation adjusted threshold, confirmed 7 August 2026.

Check the formatting rules before artwork goes to a printer:

• A distinct item on the principal display panel, separated from other printed matter.
• Generally parallel to the base of the package.
• In the bottom 30% of the principal display panel, unless that panel is 5 square inches or less.
• Stating contents excluding the package, so clamshell tare weight never counts.
• Type height scaled to panel area, at least 1/16 inch on the smallest covered panels.

State weights and measures laws may separately demand dual customary and metric declarations, or impose their own package format rules. Federal law being satisfied with ounces alone does not mean your state agrees, and a print run is something you only want to pay for once.

Nutrition Facts, and the three ways out of it

21 CFR 101.9(j)(10) expressly exempts raw fruits and vegetables from nutrition labeling, provided they carry no nutrition claim and no other nutrition information in any context, on the label, in labeling, or in advertising. The operative sentence is that claims or other nutrition information subject the food to nutrition labeling under Section 101.45. Do not confuse this with the small business exemptions: under (j)(10) a grower never proves a sales figure or an employee count, because it turns entirely on the product being raw produce and the label staying quiet about nutrition.

The low volume path has details that decide real cases. A full time equivalent is paid hours divided by 2,080. A brand new product may rely on a reasonable anticipation of fewer than 100,000 units instead of a sales history. The notice must be filed before the exemption period begins and must identify the claimant and contact, the products and brands, the relevant manufacturer, distributor or importer, the full time equivalent count, and the unit count. A non importer with fewer than 10 full time equivalents and fewer than 10,000 units need not file at all. All of that is in Section 101.9(j)(18).

For nearly every microgreens grower, (j)(10) does the work. The small business paths matter for a mixed or dressed product, which is no longer raw produce and therefore no longer covered by (j)(10) at all.

The sentence that voids your exemption

All three exemptions share one condition. A nutrient content claim, a health claim, or other nutrition information, appearing on the label, in labeling, or in advertising, ends the exemption. The regulation says claims or other nutrition information subject the food to nutrition labeling, and the small business provision separately requires labels, labeling and advertising that provide no nutrition information and make no nutrient content or health claim. Both are in 21 CFR 101.9. That word "advertising" is the trap: a market stall sign, a website product page, or a caption written by whoever runs the social account are all places an exemption goes to die.

If you genuinely want a claim on the package, get a label review before printing. The claim has to meet the Part 101 standards for its class and it simultaneously pulls you into full nutrition labeling: two compliance problems bought with one line of copy.

FDA does run a voluntary point of purchase program under 21 CFR 101.42 to 101.45, encouraging retailers to display nutrition information by signs, posters, brochures, leaflets or packages for the 20 most frequently consumed raw fruits, vegetables and fish, and participating stores may place it near the relevant food. It does not reach microgreens automatically: the Section 101.44 list is limited to those 20 commodities and microgreens are not among them. A retailer may still provide microgreens information voluntarily, but the values must be developed for the distinct product, the food name must clearly distinguish it, and Section 101.45's format and content rules then apply. Nobody hands you a compliant microgreens panel.

Two other federal rules that add a label statement

The Produce Safety Rule's qualified exemption carries a labeling duty. An eligible farm must put the name and complete business address of the farm where the produce was grown on the food packaging label, prominently and conspicuously. Under 21 CFR 112.6(b)(1) and (3), a domestic complete address means street address or post office box, city, state and ZIP Code. Where the food would otherwise carry no package label, Section 112.6(b)(2) requires the same name and complete address at the point of purchase: a label, poster, sign, placard, a contemporaneously delivered business document, or an electronic notice for internet sales. FDA's small entity guide states the requirement. Packaged product means a label; unlabeled product means a conspicuous point of sale display. It is a farm traceability duty and never substitutes for the federal label elements that independently apply. Whether you are qualified exempt in the first place is answered on the Produce Safety Rule page.

The Food Traceability Rule has an exemption with a label condition. For a Food Traceability List food produced and packaged on a farm, the exemption in 21 CFR 1.1305(b) applies only if the package stays in place until the food reaches the consumer and maintains product integrity so the food cannot later be contaminated or altered, and the consumer facing label includes the farm's name, complete address, and business phone number. FDA's produce farm fact sheet defines that address as street address, town, state, country, and ZIP or other postal code, and notes FDA may waive the phone number for a religious belief.

Read that as a condition, not a command to print a lot code on every clamshell. If your packaging will be removed or repacked before the consumer, or cannot preserve integrity, do not claim Section 1.1305(b); work out whether the product is on the list and keep the applicable records. FDA's lot code guidance says a traceability lot code is normally assigned at initial packing of a raw agricultural commodity when the entity is not exempt, and it prescribes no single label format.

One honest gap: whether microgreens are themselves on the Food Traceability List is not resolved by any federal source behind this page. Do not guess either way. Put it to your state department of agriculture's produce safety program, the office that would inspect you, and keep the written answer.

Two things people believe are required, and are not

Refrigeration statements. No general federal FDA regulation requires every package of raw produce to bear "Keep Refrigerated" or a handling statement. FDA's 1997 refrigeration document is nonbinding guidance, expressly described as the agency's current thinking, recommending model statements according to safety and quality risk rather than establishing a blanket mandate. The guidance text distinguishes "IMPORTANT Must Be Kept Refrigerated To Maintain Safety" from the optional "Refrigerate for Quality", and which fits depends on formulation and hazard assessment, not a generic microgreens rule. For cut microgreens that need cold to stay safe or saleable, a clear instruction is prudent, and a purchaser, a state rule, or a product specific safety plan may require it. Just do not present it as a federal label element.

Allergen statements on plain microgreens. As raw agricultural commodities in their natural state they are not subject to major allergen labeling, and FDA's 2025 allergen guidance answers this directly for fresh fruits and vegetables. Add an ingredient that is or contains protein from a major allergen and the answer flips. The nine major allergens are milk, egg, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame, sesame covered since 1 January 2023. Identify the food source in the ingredient list, or use a compliant adjacent "Contains" statement. A Contains statement must name all major allergen sources in the food, not only the ones the ingredient list did not already spell out. A "may contain" cross contact warning is voluntary and does not replace allergen controls.

Where state law sits on top of this

The federal baseline is identical in all 50 states, which does not mean every package carries the same final text: product facts decide whether an ingredient list, allergen disclosure, Nutrition Facts, a qualified exempt farm statement, or the traceability exemption condition applies to yours.

States commonly add requirements in seven areas: farm registration, food establishment, processor, dealer or warehouse license numbers; state or local inspection and permit statements; weights and measures rules covering customary and metric presentation, label format and random weight packages; lot, pack, harvest, sell by, use by or traceability codes; state specific country of origin, grade or commodity marketing requirements; organic certification and pesticide related documentation and claims enforcement; and refrigeration, dating or consumer safety directions for a regulated category or retail practice. Not every state imposes each one. The selling state's department of agriculture, its weights and measures division, and the local food protection authority control the practical answer.

Where a state rule directly conflicts with a valid federal requirement, federal law governs under the Supremacy Clause, U.S. Constitution article VI, clause 2, which calls federal law the supreme law of the land; Congress's own Constitution Annotated explains that federal statutes supersede inconsistent state law. There is also express food labeling preemption in the FD&C Act itself, Section 403A, codified at 21 U.S.C. Section 343-1(a): in the categories it covers, including specified identity, ingredient, allergen and nutrition labeling requirements, a state may not impose a requirement for food in interstate commerce that is not identical to the federal requirement. That statutory text is not among the sources behind this page, so treat the summary as the shape of the rule rather than a quotation. It is not blanket field preemption, which is why the seven categories above survive, and a claimed conflict is a lawyer's question rather than a reason to ignore a state agency.

Frequently Asked Questions

Q: Do I need a Nutrition Facts panel on a 2 oz clamshell of pea shoots? A: Not if the package makes no nutrition claim. 21 CFR 101.9(j)(10) exempts raw fruits and vegetables outright, with no sales or employee test to meet. The exemption ends the moment a claim or other nutrition information appears on the label, in labeling, or in advertising.

Q: Do I have to print grams next to the ounces? A: Not under federal law. Section 101.7(b)(1) requires U.S. customary weight units and Section 101.7(p) permits metric as an additional declaration. State weights and measures law is separate and may require both, so check before the print run.

Q: My mix is five varieties of microgreens. Is that a multi ingredient food? A: The research behind this page treats a package of cut microgreens as one raw agricultural food needing no ingredient list merely to repeat "microgreens", and says the analysis changes only when something beyond raw microgreens is in the package. For an all microgreens blend, no federal source here requires an ingredient list. For certainty on your specific pack, ask your state food safety program in writing.

Q: I sell at a farmers market with no printed label at all. Does anything apply? A: If you are a qualified exempt farm under the Produce Safety Rule, yes. Section 112.6(b)(2) requires the farm name and complete business address at the point of purchase when the food would otherwise carry no label: a poster, sign, placard, a business document delivered at the same time, or an electronic notice for internet sales.

Final thoughts

The federal label for a plain package of microgreens is short, and the discipline is keeping it short. Identity, net weight, responsible firm. Add the qualified exemption farm statement if it applies to you, add the traceability exemption's phone number if you are relying on Section 1.1305(b), and stop.

The failures worth guarding against are additive, not subtractive. Nobody gets in trouble for omitting a Nutrition Facts panel they were exempt from. They get in trouble for a vitamin claim on the front, a "Contains" statement naming only some of the allergens, a net weight sitting above the bottom 30%, or a state license number nobody mentioned. Before a print run, read every word on the artwork and ask of each one whether it is required, permitted, or a claim.

If your state agency tells you something that contradicts this page, tell me and I will check it. A page that is wrong about a rule is worse than no page.

Sources

Every claim above traces to one of these. All checked 7 August 2026.