by Sally Colby

Those who have added on-farm processing to the dairy farm enterprise are required to label products according to federal guidelines, and in most cases, state guidelines as well. Dr. Kerry Kaylegian, associate research professor, Penn State Food Science, discussed federal guidelines for farmers who are developing dairy food labels.

“The FDA is in charge of labeling regulations,” said Kaylegian. “They cover all the manufacturing regulations and food labeling regulations. Label requirements are found in the Code of Federal Regulations (21 CFR 101 Food Labeling). This document has all the information you need to label food products.” Information for specific dairy products is available under 21 CFR 131 Milk and Cream, 21 CFR 133 Cheese and 21 CFR 135 Frozen Desserts.

“While these don’t have anything per se about labeling, they are the standards of identity for products,” said Kaylegian. “They have the regulations on composition and sometimes manufacturing specifications you need to comply with for making those products. Before you can label the products, you need to make sure you’re making them correctly and that you meet those regulations.”

For example, heavy cream must have a minimum fat level of at least 36%. Yogurt must include two organisms – Streptococcus thermophiles and Lactobacillus bulgaricus – to legally be called yogurt. The Cheese Section includes standards of identity for more than 70 different cheeses. “If you’re making a cheese that has a named standard, you must comply with those regulations,” said Kaylegian. “For example, cheddar cheese has a maximum amount of moisture of 39%. If you make a cheddar that has 39.5%, it is no longer cheddar cheese because it exceeds the standard and can’t legally be called cheddar cheese.”

There’s also a list of cheeses that can be made from raw milk versus pasteurized milk. Although Monterey Jack, Colby and cheddar are made similarly and have similar characteristics, cheddar and Colby can be made from raw milk if the cheese is aged properly, but Monterey Jack cannot. Requirements under Frozen Desserts include specs for ice cream. For example, to be legally labeled custard, frozen custard must contain at least 1.4% egg yolk solids.

Labeling is a critical component of the package. “There are five basic things you need to have on a food label,” said Kaylegian. “Product identity, net contents, ingredient statement, nutrition statement and manufacturer information. While it isn’t specifically identified in the federal requirements, you need lot information (for traceability) as specified in FSMA regulations.”

Kaylegian described the Principle Display Panel (PDP) as the portion of a package that’s most likely to be seen by the consumer, such as the front of a box or jar. For containers that hold products such as sour cream, cottage cheese or yogurt, a portion of the label may be on the lid, and it’s called the Alternate PDP. The information panel is the portion just to the right of the PDP.

The PDP contains a statement of identity, the net contents and other required elements such as ingredient declaration, nutritional information and manufacturer information. Federal requirements state that there can be no intervening material on the information panel.

As for what goes on the label, the first consideration is product identity – the name of the food. If the product has a standard of identity, such as milk, cheese, yogurt, ice cream or butter, that product name must be used. If there’s no standard of identity, the next option is to use the common name for the product such as cheddar, feta or Greek yogurt. Kaylegian pointed out that the order requires that goat, sheep, water buffalo or other animal name appears if milk is from an animal other than cow. Labels can also include a descriptive name such as spreadable, sliced or a brief description such as “smooth and creamy.”

For flavored products, the package label must follow the regulations for flavors such as natural, artificial or WONF (with other natural flavors). Other descriptors required by the order include Grade A and/or pasteurized. The word “pasteurized” must be in type that is no larger than the product name and no less than a quarter of the size of the product name.

Homogenized and non-homogenized products must be labeled as such. Kaylegian said the word “creamline” can be used in addition to, but not in place of, the term “non-homogenized.” Products that are protein fortified or lactose reduced must be specified. The code for the location of where the product was pasteurized is also included.

The net contents of the package includes measures. “Use weight or mass measures for solid or semi-solid products such as cheese, yogurt and butter,” Kaylegian said. “Use fluid measures for liquid products such as milk, cream and ice cream. For ice cream, use measures such as fluid ounce, pint, quart, half-gallon. Measures must be in both English and metric, so also use milliliter or liter.” Weights and mass are expressed in pounds, ounces, grams and kilograms.

A critical aspect of any label is the allergen statement. “Allergens can be labeled either as an allergen or ‘contains’ statement,” said Kaylegian, noting that the FDA is strict about allergen labeling. “The big eight allergens we need to label are milk, eggs, fish, peanuts, shellfish, soy, tree nuts and wheat.” (Sesame was recently added to this list.) Since dairy products will contain milk, the label must always include an allergen statement or “contains milk” in addition to listing it on the ingredient declaration.

The nutrition statement is also located on the information panel. The requirements for this section of the label were updated in 2016 and went into effect earlier this year. Nutrition facts include servings per container, serving size (in bold type), calories (larger, bold type), macronutrients and sodium, added sugars (lactose) and mandatory nutrients including vitamin D, calcium, iron and potassium. Processors can also choose to list other vitamins and minerals.

The nutrition facts panel is usually displayed vertically, but there are also requirements for horizontal placement depending on the packaging. Standard products can usually use the USDA nutrient database for this segment, and for products that don’t fit any standard definition, product samples can be sent to certified labs to determine nutrient values. Kaylegian noted there are software programs that allow producers to make labels based on ingredients and product formulation.

Other information to include on the label is lot information. “Right now, lot information is not required in the labeling regulations,” said Kaylegian, “but it is required for traceability and is part of FSMA.” States’ regulations for sell-by dates vary, so be sure to check for details on that aspect of the label.

Information for FDA regulations can be found at The USDA nutrient database is at