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


This is Part 3 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 & Packaged on-premises

Remember, cold TCS food is any food which we always have to keep cold at 41°F or below.

  • If the food is packaged as grab-and-go, a label with the following information is required:
    • Common name of the food
    • Discard date not to exceed 7 days from the date of preparation
  • If made from two or more ingredients, a list of the ingredients in order by weight, heaviest to lightest
    • Including artificial colors, artificial flavors, or chemical preservatives
    • Separate list of any food allergens present within the food
  • FAQs
    • If a customer dining in the restaurant asks to buy a pint of my homemade pasta sauce, can I sell it to them?
      • Yes. Keep in mind, it would be a good idea to provide instructions to the customer to keep the product refrigerated, and use it within 7 days. Also, do not make any nutritional claims about the product, only that it tastes amazing.
    • A local grocery store wants to sell the salsa from my restaurant. Can I sell my product to be resold in another retail operation?
      • Short answer is no. There is an opportunity to turn this into a yes, but the long answer gets tricky. Usually, the time and financial costs prohibit a retail food service operation from scaling into a food manufacturing business, however, it can be done if someone is fully committed.
    • When is nutritional information required to be on the label?
      • When a health claim is made about the product
    • If the product will be sold in a different retail setting which is not owned by the same entity from which the product was originally made.
      • See the grocery store FAQ above. The nutrition label can be costly and very time consuming.
    • What about bakery items, such as cookies, which don’t require temperature control, or a date of any kind?
      • No label is required, as long as there is no nutritional claim or local regulation requiring a label or date.

Links to other parts in this series:

Part 1 – Dry Goods

Part 2 – TCS food Prepared and Stored on-premises

Part 4 – Commercially processed foods