Food, to label or not to label?  That is the question.


This is Part 1 of 4 on proper food labeling in retail food service establishments including, but not limited to: restaurants, cafeterias, schools, childcare facilities, hotels, healthcare facilities, street vendors, and food trucks.

The purpose of a proper label on food is not for the person who labels it. Rather, a label on food is the ONLY way to communicate anything relevant about the food to anyone else looking at it. Also, one of the most frequent items health inspectors will find when conducting inspections is improperly labeled food. So, let’s clarify what needs to be labeled, and if so, what information is required.

Links to the other three parts are at the bottom.

Key terms:

  • TCS foods – Foods which require constant time/temperature control to maintain safety.

Labeling Dry Food Items

Common examples are uncooked pasta, rice, flour, sugar, oils, potato flakes, etc.

  • If the product is umistakably identifiable, such as dry pasta, no label is required.
  • If the product is in the original container or packaging, then no label is required.
    • Example: An unopened 50 pound bag of sugar sitting on a shelf in dry storage doesn’t need to be labeled with anything because anyone looking at it can clearly see “sugar” printed on the bag.
  • If the product has been opened and put into another food storage container, then a label with the common name of the food is required.
    • Example: The 50lb. bag of sugar was poured into a food storage bin, then anyone looking at the bin needs to know the contents. If no label is present, then someone could easily mistake the contents for being salt.
  • If the product has been opened and will remain in its original packaging, then the product does need to be wrapped or placed into a clear plastic bag. Therefore, the common name “sugar” is clearly still visible through the clear plastic. We are not supposed to leave opened packages of food sitting in dry storage.
    • Example: Once opened, a 5 pound bag of sugar would need to be placed in a zip-lock bag, thus allowing someone to still see “sugar” printed on the packaging.
  • FAQ
    • What if I combine multiple items, such as making a special seasoning?
      • The special seasoning needs to be labeled with the common name, regardless. The common name might be something which is made up, but specific to the food service operation.
      • Example: The “secret” chicken spices should be labeled with “Secret Chicken Spice Blend”.

Links to the other parts of the series:

Part 2 – TCS food Prepared and Stored on-premises

Part 3 – TCS food Prepared and Packaged on-premises

Part 4 – Commercially processed foods