As I understand it, the FDA requires labeling with specific information for food and supplement products in most cases, and steep potential penalties for "misbranding" if required information is missing from the label. When food is sold in bulk in grocery stores, the required information is (in my experience) posted on or near the bin. However, I have seen cases in which bulk food or supplement products are sold online and arrive in simple ziploc bags or other unlabeled packaging. Provided that required label information is given in the online product listing, is this legal? Or are these vendors skirting FDA regulations?

In other words, what counts as a "label" for the purpose of FDA labeling requirements? Could it be e.g. the product page on an e-commerce platform?

1 Answer 1


The FDA has an FAQ with citations to legal authority regarding its labeling requirements.

Generally speaking, food sold to the general public in packages must be labeled. There are exceptions for some farmer's market scale face to face dealings and for bulk food sales, but none that would obviously apply to internet sales of food, which is almost by definition, packaged food for sale which is subject to the labelling requirement. The main exemptions are set forth in 21 CFR § 1.24.

Most of the regulatory detail applies to the content of the labels rather than the requirement that products have a label.

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