FDA vs UK Food Labeling: A Side-by-Side Guide
If you sell packaged food in both the United States and the United Kingdom, you are working with two food labeling systems that look superficially similar and behave very differently. The number of mandatory allergens, the layout of the nutrition information, the units, the serving-size logic and even the way allergens are declared on the pack all diverge. This guide puts US FDA labeling and UK labeling side by side so you can see exactly where they differ — and how to manage one recipe across both markets without maintaining two separate systems.
Two systems, two regulators
The starting point is that US and UK food labeling are governed by entirely separate bodies of law. In the United States, packaged food labeling is regulated by the Food and Drug Administration (FDA) under the Federal Food, Drug, and Cosmetic Act, with allergen rules set by the Food Allergen Labeling and Consumer Protection Act (FALCPA) as amended by the FASTER Act. In the United Kingdom, labeling is governed by the Food Information Regulations 2014 (FIR 2014) — the UK's implementation of retained EU food information law — and, for food packed for direct sale, by the Food Information (Amendment) (England) Regulations 2019, commonly known as "Natasha's Law."
Because the two systems evolved independently, a label that satisfies the FDA does not automatically satisfy UK requirements, and vice versa. The differences are not cosmetic: they affect which allergens you must declare, how nutrition is presented, what units appear on the pack, and how serving sizes are calculated. The rest of this guide walks through each of these dimensions and ends with how a single recipe database can output both formats. If you sell into the US specifically, our US compliance software overview goes deeper on the American side.
Allergens: the Big 9 versus the 14
The most consequential difference between the two markets is the allergen list. The US recognizes 9 major allergens — the "Big 9" — while the UK requires declaration of 14 named allergens. These lists overlap substantially, but they are not the same, and the gap is exactly where cross-market businesses get caught out.
The US Big 9 (FALCPA + FASTER Act)
Under FALCPA, as amended by the FASTER Act, the US major allergens are:
- Milk
- Eggs
- Fish
- Crustacean shellfish
- Tree nuts
- Peanuts
- Wheat
- Soybeans
- Sesame
Sesame is the newest addition. The FASTER Act made sesame the 9th major food allergen in the US, with the labeling requirement taking effect on 1 January 2023. Before that date, US labels recognized only the "Big 8." Our detailed breakdown of the US list lives in FALCPA and the Big 9 allergens, and the sesame transition specifically is covered in the FASTER Act sesame labeling guide.
The UK 14 named allergens (FIR 2014)
Under FIR 2014, UK food businesses must declare the following 14 allergens:
- Cereals containing gluten (wheat, rye, barley, oats and their hybrids)
- Crustaceans
- Eggs
- Fish
- Peanuts
- Soybeans
- Milk
- Tree nuts
- Celery
- Mustard
- Sesame
- Sulphur dioxide and sulphites (above 10 mg/kg or 10 ml/L)
- Lupin
- Molluscs
The five allergens the UK requires that are not part of the US Big 9 are celery, mustard, sulphites, lupin and molluscs. This means a recipe that has been correctly labeled for the US could easily be missing mandatory UK declarations. A dressing containing celery and mustard, or a dried fruit treated with sulphites, would carry no major-allergen declaration on a US "Contains" statement but would need both called out in the UK. The UK list is explained in full in The 14 major allergens under UK law.
How allergens are declared on the pack
The two markets also differ in how allergens appear. In the US, the dominant approach is a separate "Contains" statement placed at or near the end of the ingredient list — for example, "Contains: Milk, Wheat, Soy." FALCPA also permits declaring the allergen source in parentheses within the ingredient list, but the "Contains" statement is the most common and most recognizable US convention. The mechanics of building US allergen declarations are covered in our FALCPA allergen labeling software page.
In the UK, there is no standalone "Contains" box. Instead, allergens must be emphasized within the ingredients list itself — typically by setting the allergen word in bold (and sometimes in capitals or a contrasting font). So a UK ingredient list reads "wheat flour, milk, sugar, egg" with the allergens standing out in the body of the list, rather than being repeated in a summary line. This bold-in-list approach is also what Natasha's Law requires for food packed for direct sale (PPDS).
Nutrition information: Nutrition Facts panel versus back-of-pack table
The second major divergence is the nutrition panel. The two markets present essentially the same underlying data in formats that are not interchangeable.
The US Nutrition Facts panel (21 CFR 101.9)
The FDA Nutrition Facts panel is defined in 21 CFR 101.9 and is built around a serving size and % Daily Values (%DV). Calories are shown prominently in large type. The panel breaks out Total Fat, Saturated Fat, Trans Fat, Cholesterol, Sodium, Total Carbohydrate, Dietary Fiber, Total Sugars and — importantly — Added Sugars, a line the UK table does not use. It then lists four mandatory micronutrients: Vitamin D, Calcium, Iron and Potassium.
The %DV figures are based on a set of daily reference values, and the panel carries a footnote stating that "%DV tells you how much a nutrient in a serving of food contributes to a daily diet. 2,000 calories a day is used for general nutrition advice." The underlying reference Daily Values include Total Fat 78g, Sodium 2,300mg, Total Carbohydrate 275g and Added Sugars 50g, among others. If you only need the US panel, see our dedicated FDA Nutrition Facts label software, and for a small-business walkthrough, FDA Nutrition Facts label requirements for small businesses and how to create an FDA-compliant food label.
The UK back-of-pack nutrition table
The UK uses a back-of-pack nutrition table reported per 100g (or per 100ml for liquids), with an optional additional "per portion" column. The mandatory nutrients are: energy (shown in both kJ and kcal), fat, of which saturates, carbohydrate, of which sugars, protein, and salt. Note "salt," not "sodium" — the UK reports salt directly. The UK table does not use % Daily Values in the same prominent way the US panel does, does not separate out added sugars, and does not require the four US micronutrients. Many UK products also carry front-of-pack "traffic light" labeling, but that is a separate voluntary scheme layered on top of the mandatory back-of-pack table.
Units and serving sizes
The unit systems differ as you would expect. US net-quantity statements use US customary units — ounces, pounds and fluid ounces — almost always shown alongside a metric equivalent (the dual declaration, e.g. "NET WT 12 oz (340g)"). Within the Nutrition Facts panel, nutrients are reported in grams and milligrams. UK labels are metric throughout: grams, kilograms, millilitres and litres, with the nutrition table reported per 100g or per 100ml.
Serving-size logic also diverges. The US uses Reference Amounts Customarily Consumed (RACC) — standardized reference amounts set by the FDA for each food category — to determine the serving size that anchors the Nutrition Facts panel. The UK, by contrast, anchors its mandatory nutrition declaration to a per-100g (or per-100ml) basis, with per-portion figures optional. This means the "denominator" of the two panels is fundamentally different: the US figure is per serving (driven by RACC), while the UK figure is per 100g.
Side-by-side comparison table
The table below summarizes the main differences between US (FDA) and UK (FSA) food labeling for packaged food. Note that the Food Standards Agency (FSA) is the UK's food safety body; the underlying rules sit in FIR 2014 and Natasha's Law.
What this means for businesses selling in both markets
If you sell into both the US and the UK — a specialty bakery shipping to American customers, a sauce brand on US and UK shelves, a meal-prep business with transatlantic wholesale — you are effectively maintaining two label systems for the same products. Done manually, this is where errors creep in: a US label missing the UK's celery declaration, a UK pack that quotes calories but not kJ, a Nutrition Facts panel reused where a back-of-pack table is needed, or a "Contains" statement carried over to a market that expects bold-in-list emphasis.
The root cause is that the recipe data is the same, but the label output must differ by market. The efficient approach is to hold one accurate recipe and ingredient database, then generate the correct output format per market from that single source of truth. That is exactly the problem FoodCore's "Both" Compliance Region mode is built to solve.
How FoodCore's "Both" Compliance Region mode works
FoodCore lets you set a Compliance Region of US, UK, or Both. In "Both" mode, you maintain a single recipe and ingredient database — enter each ingredient once, build each recipe once — and FoodCore generates market-specific outputs from the same data:
- US output: an FDA-format Nutrition Facts panel with % Daily Values, structured for 21 CFR 101.9, plus a "Contains" allergen statement covering the Big 9.
- UK output: a back-of-pack nutrition table per 100g (energy in kJ and kcal, fat, saturates, carbohydrate, sugars, protein, salt) and, where relevant, a Natasha's Law PPDS label with the 14 allergens emphasized in bold within the ingredients list.
- Per-market allergen flagging: FoodCore flags the correct allergen set for each market — the Big 9 for the US and the 14 named allergens for the UK — so it surfaces, for example, that a recipe containing celery and mustard needs extra UK declarations even though the US "Contains" line stays the same.
This means you do not maintain two parallel systems or re-key data per market. You change a recipe once, and both the US and UK outputs update from the same source. You can explore the full feature set on the product page, and the US-specific outputs on our US food labeling software page. Costing, including ingredient costs, runs through the recipe cost calculator.
A note on pricing and currency
Because FoodCore supports both markets, it is worth being clear about currency. Within the platform, USD applies to costing only — you can cost recipes and ingredients in US dollars if you operate in the US. The FoodCore subscription and AI credits, however, are billed in GBP regardless of which Compliance Region you select. This is purely a billing detail and has no bearing on which label formats you can generate.
Getting started across both markets
If you are expanding from one market into the other, the practical first step is to get your ingredient and recipe data into a single system and let it produce both label formats, rather than rebuilding everything twice. FoodCore offers a self-serve trial at signup.foodcore.io with a 7-day free trial and no card required, so you can set the Compliance Region to "Both," build a couple of representative products, and see the US Nutrition Facts panel and the UK back-of-pack table generated side by side from the same recipe. You can also start directly from get started.
This article is general information, not legal advice. Food labeling compliance — in both the US and the UK — is ultimately the responsibility of the food business. Always verify your labels against the current regulations and, where appropriate, take professional advice. FoodCore assists with generating and managing labels; it does not assume legal responsibility for your declarations.
FDA vs UK food labeling: frequently asked questions
What is the main difference between FDA and UK food labeling?
The biggest practical differences are the allergen list and the nutrition format. The US FDA recognizes 9 major allergens (the Big 9: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame) and typically declares them in a separate "Contains" statement, while the UK recognizes 14 named allergens and requires them to be emphasized in bold within the ingredients list. For nutrition, the US uses the FDA Nutrition Facts panel with % Daily Values and US customary units, while the UK uses a back-of-pack table reported per 100g with energy shown in both kJ and kcal. Beneath these, the legal frameworks differ: FALCPA and the FASTER Act in the US versus the Food Information Regulations 2014 and Natasha's Law in the UK.
How many allergens must be declared in the US versus the UK?
The US declares 9 major allergens under FALCPA as amended by the FASTER Act: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame (sesame became the 9th major allergen on 1 January 2023). The UK declares 14 named allergens under the Food Information Regulations 2014: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts, celery, mustard, sesame, sulphur dioxide and sulphites, lupin, and molluscs. The UK's extra five — celery, mustard, sulphites, lupin and molluscs — are not part of the US Big 9, so the same recipe can carry different mandatory declarations in each market.
Is the FDA Nutrition Facts panel the same as the UK nutrition table?
No. The FDA Nutrition Facts panel (21 CFR 101.9) is built around a serving size and % Daily Values, lists Calories prominently, and breaks out Added Sugars and several micronutrients (Vitamin D, Calcium, Iron, Potassium), with a 2,000-calorie footnote. The UK back-of-pack table reports values per 100g (and optionally per portion), shows energy in both kJ and kcal, and lists fat, saturates, carbohydrate, sugars, protein and salt — it does not use % Daily Values in the same way and does not separate added sugars. The two formats are not interchangeable; a product sold in both markets needs both panels.
What units are required on US versus UK food labels?
US labels use US customary units (ounces, pounds, fluid ounces) for net quantity, almost always shown alongside metric equivalents, and the Nutrition Facts panel uses grams and milligrams for nutrients. UK labels use metric units throughout — grams, kilograms, millilitres and litres — and the nutrition table is reported per 100g or per 100ml. If you sell in both markets you will typically need dual net-quantity statements and two different nutrition layouts.
How does FoodCore help businesses selling in both the US and the UK?
FoodCore offers a "Both" Compliance Region mode. You maintain a single recipe and ingredient database, and FoodCore can output an FDA-format Nutrition Facts panel with % Daily Values for the US and a UK back-of-pack nutrition table or PPDS label for the UK from the same underlying data. It also flags the correct allergen set per market — the Big 9 for the US and the 14 named allergens for the UK — so you don't have to maintain two separate systems. The US panel is FDA-format and should be verified against the regulations and your own values before printing.
Does FoodCore produce a fully FDA-validated label?
FoodCore generates an FDA-format Nutrition Facts panel with % Daily Values; it uses standard rounding rather than reproducing every exact FDA rounding increment, so the panel should be treated as a strong starting point that you verify before printing. The label designer also does not automatically enforce ingredient descending-weight order, dual net-quantity statements or "Distributed by" wording, and US micronutrient values (Vitamin D, Calcium, Iron, Potassium) are placeholders unless you supply lab values. The AI assistant reasons under FDA, FALCPA and the FASTER Act to help you spot issues, but final compliance is always the business's responsibility.
Can the same recipe be labeled for both markets without changes?
Usually not without some adjustment. Even when a recipe is identical, the US and UK require different allergen sets, different nutrition formats, different units and different declaration methods. A product that only declares the Big 9 may be missing UK allergens such as celery, mustard, sulphites, lupin or molluscs, and a UK back-of-pack table cannot stand in for a US Nutrition Facts panel. The recipe data can be shared, but the label outputs must be generated separately for each market — which is exactly what FoodCore's "Both" region mode is designed to do.
Further resources
- FDA food labeling and nutrition guidance
- FSA allergen guidance for food businesses
- FALCPA and the Big 9 allergens (US)
- FASTER Act sesame labeling guide
- FDA Nutrition Facts label requirements for small businesses
- How to create an FDA-compliant food label
- The 14 major allergens under UK law
- Natasha's Law 2026 compliance refresher
- FoodCore US food labeling software
- FoodCore FDA Nutrition Facts label software
FoodCore is kitchen management software for food businesses in the US, the UK, or both. Set your Compliance Region and generate an FDA-format Nutrition Facts panel, a UK back-of-pack table or a Natasha's Law label — all from one recipe database.
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