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


This is Part 2 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.

TCS food Prepared & stored on-premises

Remember, cold TCS food is any food which we always have to keep cold at 41°F or below. Common examples would include soups, sauces, salads (i.e. chicken, egg, greens, tuna), salad dressings, salsas, and the like.

  • If the food is used within 24 hours, ONLY the common name of the food is required.
    • Example: Food made only for a specific event such as a wedding reception or company lunch, and any leftover food is given away or discarded after the event.
  • If the food is kept longer than 24 hours, then a label with the common name AND a DISCARD DATE not to exceed 7 days from the date of preparation is required.
    • Example: A chicken wing restaurant makes 5 gallons of ranch dressing on January 1st. The label should read –
      • Ranch dressing
      • Discard on: Jan. 7th
  • Uncultured dairy products such as milk, half & half, heavy cream, etc.
    • Open date and/or discard date is required.
    • The container has a shelf life of 7 days starting with the date the container was opened.
    • Fun note: The dairy product can be used past the manufacturer “best if used by” date, as long as
  • FAQs
    • Can the day of prep be used instead of the discard date?
      • In most cases, yes. This does depend on the specific health department jurisdiction you are in, but most will accept the date of prep. However, make sure you do have a system which provides full clarity for discarding the food once it reaches the 7 day shelf life.
      • The best practice is to put both the date of preparation and the discard date.
    • Why is the shelf life 7 days?
    • The bacteria Listeria is the primary concern. This bacteria is prevalent in most kitchens already, and is therefore likely to be introduced into any foods which we prep on-premises. This bacteria is also unique in that it will grow slowly under refrigerated conditions, and based on growth rates of the bacteria, it can grow to levels high enough to make someone sick after 7 days.

Links to other parts in series:

Part 1 – Dry Goods

Part 3 – TCS food Prepared and Packaged on-premises

Part 4 – Commercially processed foods