Everything a food label is required to say, the name, ingredients, allergens, net quantity, Nutrition Facts and the name and address, has to appear in English. A label can use another language too, and many do, but there's a catch: if the label has any representation in a foreign language, all of the required information has to appear in that language as well. So a frozen pack called "Pupusas de Queso" on the front, with an English-only ingredient list and Nutrition Facts on the back, is missing its Spanish. The fix is either a fully bilingual label, or keeping the foreign words off. Packages sold only in Puerto Rico or a territory where another language predominates can use that language instead of English. In the example below, a Houston pupusa maker relabels its frozen packs.
The short version
- Required information appears in English.
- Any foreign-language words on the label bring all required information in that language too.
- That means the name, ingredients, allergens, net quantity, Nutrition Facts and name and address.
- Either go fully bilingual, or keep the foreign words off.
- Puerto Rico and some territories can use their predominant language.
- Tiny single-serve packages for restaurants are exempt when only the name is foreign.
- TaroStack keeps each product as a recipe and each batch as a lot. More below.
What the label needs
| The label | What it needs |
|---|---|
| English only | All required information in English |
| English, with a Spanish name or slogan on the front | All required information in Spanish too |
| Fully bilingual, English and Spanish | Complete in both |
| Sold only in Puerto Rico | Spanish may replace English |
| A small single-serve packet for restaurants, only the name in Spanish | Exempt from the second language |
Where the name goes is in statement of identity food label, and the allergens in food allergen labeling requirements.
The rules
| Rule | Where |
|---|---|
| English | All required words, statements and information appear in English, except in Puerto Rico or a territory where another language predominates (21 CFR 101.15(c)(1)) |
| Any foreign language | If the label contains any representation in a foreign language, all required information appears in that language as well (101.15(c)(2)) |
| Small packets | Single-serve packages of 1.5 oz or less served with meals in restaurants, not for retail sale, are exempt when only the name is foreign (101.15(c)(2)) |
| Labeling | If labeling other than the label, such as a leaflet, has foreign words, it carries all required information (101.15(c)(3)) |
This is general information, not legal advice.
An example: a frozen pack
La Ceiba Pupusería, the made-up pupusa truck in Houston, Texas, I use in these examples, sells frozen six-packs to four Latin grocers. The front said "Pupusas de Queso"; the back was in English only:
| Part of the label | Before | After |
|---|---|---|
| Name on the front | "Pupusas de Queso" | "Pupusas de Queso / Cheese Pupusas" |
| Ingredients and allergens | English only | English and Spanish: "Ingredientes", "Contiene: leche" |
| Net quantity | "Net Wt 24 oz (680 g)" | Also "Peso neto 24 oz (680 g)" |
| Nutrition Facts | English panel | A bilingual panel |
| Name and address | English | The same, with "Elaborado por" beside it |
The owner chose a fully bilingual label, because the grocers' shoppers read Spanish first; the other route was a front with only English. A bilingual Nutrition Facts panel follows FDA's format with both languages. The pupusas themselves are in pupusa business plan.
Get the checker
Download the bilingual label checker. One sheet: each required element of the label and whether it appears in English and in the second language, and whether the label has any foreign words at all; what's missing fills in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The checker lists what's missing. When the recipe changes, both languages have to change on the same print run, or the Spanish ingredient list falls a version behind the English.
How TaroStack does it
TaroStack keeps each pupusa as a recipe and each batch as a lot, so what's in a package, and who got it, is on record.
Recipes by weight. Each pupusa is a recipe with its ingredients by weight, so a recipe change shows which labels it touches.
Batches by lot. Each batch records the recipe and ingredient lots it used, and lot labels print for the cases.
Recalls. If a batch went out with the wrong label, one report shows every customer who got it.
| The job | Notebook | In TaroStack |
|---|---|---|
| Which recipe a batch followed | Remembered | Each batch from its recipe |
| Which batch a package came from | Written on it | The lot on its label |
| Who got a mislabeled batch | Invoices | One recall report |
Recipes, batches, lots and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.