How to Label Freeze-Dried Food and Candy for Sale

This guide covers the federal rules for packaged food in the US. Your state’s cottage food law can add its own required statements, and those come first if you sell under a cottage food permit. It isn’t legal advice; your health department reviews labels for free in many states, and it’s worth asking.

The five parts every label needs

What it is. The statement of identity, on the front: “Freeze-dried strawberries”, “Freeze-dried sour gummy worms”. Say it’s freeze-dried; that’s part of what the product is.
How much is in it. Net weight in both US and metric units, on the bottom of the front panel: “Net wt 1.5 oz (42 g)”.
Ingredients, in descending order by weight.
Allergens. The major food allergens the product contains.
Who made it. The name and address of the maker, packer or distributor.

The sixth element, the Nutrition Facts panel, is where small businesses get a break.

The Nutrition Facts exemption, and how to lose it

FDA rules exempt small sellers from the Nutrition Facts panel in two ways, set out in its small business exemption guide. If your business has annual gross sales of $500,000 or less, or annual food sales to consumers of $50,000 or less, you’re exempt with nothing to file. A separate low-volume exemption covers a product when your business has fewer than 100 full-time-equivalent employees and sells fewer than 100,000 units of that product a year in the US; for that one, a notice is filed with FDA every year.

The catch is in the marketing. FDA’s guidance says that if any nutrient content claim, such as “sugar free”, a health claim, or other nutrition information appears on the label, in labeling or in advertising, the exemption doesn’t apply to that product. “Healthy”, “low calorie”, “high fiber” and “no sugar added” on your bag, your website or your market sign all count. Describe taste and texture instead: “crunchy”, “intensely sour”, “made in small batches”.

Ingredients and allergens when you start from someone else’s candy

If you freeze-dry a candy you bought, its ingredients become yours. Copy the ingredient list from the original package in the same order, including the sub-ingredients, and copy its allergen statement too. A mix of several candies needs every ingredient from every candy, ordered by weight across the whole bag.

The US has nine major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Sesame joined the list on January 1, 2023, so check older packaging and supplier sheets. If you also run nut or dairy products through the same machine, say so; shared equipment is the claim most likely to end up in front of a customer’s doctor.

Weigh after drying

Freeze-drying removes water, and water is most of the weight of fruit. Strawberries lose around nine-tenths of their weight. Candy loses much less, but gummies and taffy still lose some. Your net weight has to describe what’s in the bag, so set it by weighing finished product, and fill to a target a little above the stated weight so normal variation never puts a bag under.

Dates are optional, but choose the right words

Except for infant formula, federal regulations don’t require a date on food, according to USDA’s Food Safety and Inspection Service. If you do print one, FSIS recommends “Best if Used By”, which tells shoppers the date is about quality rather than safety. Set the date from your own storage tests in the packaging you actually sell in, and keep it conservative. Some states and cottage food programs set their own rules, so check yours.

Cottage food statements

Most states that allow home-kitchen sales require a statement on the label, often that the food was made in a home kitchen not inspected by the health department. The exact wording, type size and placement vary by state and are spelled out in the cottage food rules. Use your state’s wording word for word.

Branded candy on your label

Freeze-dried versions of famous candies now sell under their own brands in supermarkets. If you freeze-dry a branded candy, describe your product in your own words and list the original candy in the ingredients, rather than putting another company’s brand name in your product name. Talk to an attorney before you use a brand name anywhere on the front of the bag.

A label checklist

Front: product name with “freeze-dried”; net weight in oz and g in the bottom 30% of the panel.
Back: ingredients by weight, “Contains:” allergen line, maker’s name and address.
Your state’s cottage food statement, if you sell under a cottage food permit.
No nutrition or health claims anywhere, unless you add a Nutrition Facts panel.
A “Best if Used By” date from your own tests, if you use a date at all.
A lot code or batch date, so a problem can be traced to one batch.

How to label freeze-dried food and candy for sale