When a Taiwanese granola-powder maker translated their local nutrition table into English and printed it on the export packaging, the shipment was flagged in Los Angeles: wrong serving basis, no Added Sugars line, three mandatory minerals missing, and a panel layout that was not the FDA format at all. The owner was baffled — “the numbers are all real, why is this a problem?” Because the US does not only regulate the numbers; it regulates how you present them.
Written by SKYCARGO INC, a US logistics company shipping between the US and Taiwan since 2014 and incorporated in the US in 2023, with warehouses in Oregon, Los Angeles and Taoyuan; it serves as an FDA U.S. Agent and can assist clients with USDA registrations and inquiries. More on this topic: US Food & FDA Compliance: The Complete Guide Index.
Which version is the “new” Nutrition Facts
FDA’s updated Nutrition Facts label took effect on July 26, 2018, and became mandatory for large manufacturers on January 1, 2020 — and it applies equally to imported packaged food. If your product sits on a US shelf, it follows the same panel rules as domestic products. For new export projects, build the new format from day one; do not adapt an old-format template.
The key changes:
- Serving Size must reflect what people actually eat: FDA publishes Reference Amounts Customarily Consumed (RACC) per food category — you do not get to invent your own basis
- Calories in large bold type: the most prominent number on the panel
- Added Sugars is a new mandatory line, broken out under Total Sugars with its own %DV
- Vitamin D, potassium, calcium and iron are mandatory; vitamins A and C became voluntary
- %DV values recalculated against the updated daily reference values
Taiwan label vs US label: a straight translation always fails
| Item | Taiwan label | US new format |
|---|---|---|
| Sugars | Total sugars only | Total Sugars + Added Sugars split |
| Minerals | Not mandatory | Potassium, calcium, iron mandatory |
| Vitamins | Not mandatory | Vitamin D mandatory |
| Logic | Focus on “limit these” (calories, fat, sodium, sugar) | Both limit-nutrients and encouraged nutrients |
| Language and layout | Chinese, flexible format | English, FDA-prescribed layout |
Taiwan’s label logic is a warning about what to eat less of; the US logic is full disclosure, minerals included. So the columns your Taiwan label never had are not a translation gap — they are data you have never tested or calculated, and you need to go back and generate them.
Dual-column labels: mix-and-prepare products
Powdered drinks, soup bases and concentrates — products sold in one form and consumed in another — fall under dual-column labeling: one column as sold (for example per scoop of dry powder), one column as prepared per the package instructions. The granola-powder client in the opening was exactly this case: they labeled the dry powder only. Dual columns are not extra credit; if your product qualifies, they are required.
Where the numbers come from: data first, label second
The panel layout is the last step. The practical sequence: once the recipe is locked, send the finished product to a lab for nutritional analysis (or calculate from a reliable ingredient database), get the per-100g values, convert to per-serving numbers using your defined serving size, then typeset into the FDA format. Keep the lab report — your FSVP importer will check your label numbers against it during supplier verification. If the recipe changes or the label is revised, rerun the data; do not reuse a three-year-old report.
The most common ways to fail
- Shipping with the Taiwanese label as-is, or a small English sticker pasted over it → detention
- Adapting an old-format template (no Added Sugars, wrong type sizes)
- Inventing a serving size far from the FDA reference amount
- Label numbers that do not match the lab report — surfaced the moment your FSVP importer verifies
How SKYCARGO helps
SKYCARGO INC serves as an FDA U.S. Agent and can assist clients with USDA registrations and inquiries. The Importer of Record is normally you, as a non-resident importer; we help line up the paperwork, and entries are filed through our partner licensed customs broker. We act as Importer of Record for a client’s goods only under specific conditions; see Importer of Record duties explained. Before you print, we help review the English label and Nutrition Facts layout; once the goods land, the same team coordinates customs entry through the broker, FDA examination and warehouse distribution. Documents we assist with, freight we carry — label problems should be fixed in Taiwan, not discovered at the pier. Personal-use consolidation is outside this site’s scope — use Shiptw consolidation.
Building your first US-format label? Send us your product category and current label and we will reply within one business day with the gap list.
This article summarizes FDA nutrition labeling requirements for reference only. Specifics change; confirm against current FDA publications and formal regulatory advice for individual cases.
