A scallion pancake sold in Taiwan for ten years without a problem gets held at US customs by FDA for “label non-compliance”: the ingredient list puts “flour” after “scallion,” allergens are not declared separately, and the nutrition panel is in the Taiwanese format. This is not just GoodMall’s story — it is the most common reason for refusal among the Taiwanese foods we handle. The food-safety tests usually pass; the label is where most first-time exporters trip.
US food labeling rules are written in 21 CFR Part 101, and that is what FDA checks against when it samples at the port. The seven points below are where Taiwanese producers go wrong most often. Check them yourself before shipping and you save the time and cost of a refusal.
1. Ingredients in descending order by weight, using US common names
Taiwanese labels tend to put the selling point first; the US requires strict descending order by weight. Ingredient names must also be the common names FDA recognizes: “soy sauce” must be written as soy sauce and broken out into its components (water, soybeans, wheat, salt), and “spices” cannot be used to gloss over items that contain allergens. Compound ingredients must be expanded in parentheses all the way down.
2. Allergens must be declared separately — and the US has nine
The US Major Food Allergens are nine: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and — since 2023 — sesame. Declare them one of two ways: in parentheses within the ingredient list, or in a separate “Contains: wheat, soy” line below it. What Taiwanese producers miss most often is sesame, and the rule that “fish” must name the species (for example Contains: fish (milkfish)).
3. The nutrition panel must use the US Nutrition Facts format
FDA does not accept Taiwan’s nutrition label table. Nutrition Facts has a fixed layout: serving size in common US units, calories per serving in enlarged type, and mandatory lines for total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fiber, total sugars, added sugars, protein, vitamin D, calcium, iron and potassium. Small packages may use a simplified format, but you cannot drop items on your own.
4. Net weight in both units, in a fixed position
Net weight must appear in both US customary and metric units, for example Net Wt 8 oz (227 g), in the bottom third of the principal display panel, with a minimum type size that depends on package area. Grams only, or net weight hidden on the back, are both common grounds for refusal.
5. Name and address of the manufacturer or distributor
The label must carry the name and address of the manufacturer, packer or distributor. If it shows a US distributor, add “Distributed by” or “Imported by”; foreign products must also state the country of origin, “Product of Taiwan.” Many producers print only the Taiwanese plant address with no US contact at all, and FDA asks for a correction.
6. Claims have strict definitions
“Natural,” “Healthy,” “Low Fat” and “Sugar Free” all have regulatory definitions in the US and cannot be printed the way they are in Taiwan. Chinese claims such as “no additives,” “natural” or “wellness,” once translated into English, often run into FDA’s limits on health claims. The safest approach is to remove every claim, get the product in first, and then evaluate each claim against the rules.
7. Chinese may stay, but the English must be complete
The US allows bilingual labels, but every mandatory element must be in English, and the English may not be less complete than the Chinese. The common mistake is a full Chinese label with only a simplified English sticker — or an English sticker that half-covers the Chinese net weight and ingredients. The right approach is to redesign a complete English label, with Chinese as the supplement.
All seven correct — one more thing
Label compliance is FDA’s first impression at inspection, but not the only one. Facility registration, Prior Notice and an FSVP Importer all have to be in place before the cargo gets in. SKYCARGO INC holds FDA and USDA agent status and can act as Importer of Record and consignee; before shipping we review the labels, check them against the ingredient list and test reports, and then file the Prior Notice. GoodMall scallion pancakes went on shelf only after the label was adjusted to the US format, and every lot since has been released without issue.
If you want to know whether your label will pass before you ship, send us your current label and ingredient list and we will reply within one working day with the items that need changing.
This article summarizes FDA 21 CFR Part 101 food labeling rules for reference only. Actual requirements depend on product category and the latest FDA announcements.
