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


This is Part 4 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.

Commercially processed foods

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

  • Follow the food manufacturer guidelines.
  • If the product has manufacturer guidance to use within a specific time frame from when the product is opened, then an open date is required on the product.  Common food items included would be cole slaw, potato salad, pimento cheese, hummus, guacamole, etc.
    • Example: The lid of the pimento cheese has a statement of – “Use within 1 month of opening.”  We must mark or label the container with the day the container was opened.
  • Bulk container products which are made at a food manufacturing facility, such as mayonnaise, salad dressings, mustard, ketchup, and sauces do NOT require any type of date marking.
    • Fun note! Officially, these products are not even required to be refrigerated! These products are refrigerated for quality control rather than food safety.
    • However, if we have changed the product by adding something to these products, or modified it from the original commercial processing, then a label with a discard date to use within 7 days is required.
      • Example: If we took stock mayonnaise and added ingredients to make an aioli, then date marking like any other food with a 7 day shelf life is required.
  • Exceptions which do NOT require any kind of labeling or date marking:
    • Hard cheese which contains less than 39% moisture, such as cheddar, gruyere, parmesan and romano
    • Semi-soft cheeses with a moisture content between 39%-50%, such as blue cheese, edam, gorganzola, gouda, and monterey jack
    • Cultured dairy products such as yogurt, sour cream, and buttermilk
    • Dry fermented and shelf stable sausages such as pepperoni and Genoa
    • Shelf stable salt-cured products such as prosciutto and Parma
    • Preserved fish products such as pickled herring and dried or salted cod
  • FAQs:
    • There isn’t a definitive date of the food product, so how am I supposed to know if I need to put a date on it?
      • Contact us! We’re happy to help with any questions!
    • Or, go ahead and put a label with a date on the food item, and make a note to ask the inspector next time you see them.

Links to other parts in series:

Part 1 – Dry Goods

Part 2 – TCS food Prepared and Stored on-premises

Part 3 – TCS food Prepared and Packaged on-premises