Making Sense of FDA’s New Dual-Column Nutrition Facts Label Requirement for 2-3 Servings

Photo caption: This is a dual-column label indicating the nutrition facts of a single bagel, as well as if a consumer ate the entire package of bagels.RACC Changes

According to the FDA, “by law, serving sizes must be based on amounts of foods and beverages that people are actually eating, not what they should be eating. How much people eat and drink has changed since the previous serving-size requirements were published in 1993.” As such, the FDA has updated some of the Reference Amounts Customarily Consumed (RACC) serving sizes to reflect serving sizes that Americans actually eat. For example, the RACC serving size for carbonated beverages, such as soda, has increased from 8 fl oz to 12 fl oz. This is important because the RACC determines what your package’s serving size is and what nutrient content claims you are eligible to make. (More on this later.)


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Photo caption: This is an example of a label showing a single serving of soda (20 fl oz). Originally, the servings-per-container could state “About Two Servings;” now, it must be listed as one serving per containerSingle-Serving Container Rule

Take Note! A product that is packaged and sold individually and contains fewer than two servings (200% of the RACC) is now to be labeled as a single serving. Previously, for packages that contained fewer than two servings, you could list “About Two Servings;” now, it must be listed as one serving per container.

For example, the RACC for a carbonated beverages is 12 fl oz. Therefore, both a 12-fl-oz and 20-fl-oz bottle of soda should be labeled as one serving. (However, a 24-fl-oz bottle would require a dual-column label because it is 200% of the 12-fl-oz RACC.)


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Photo caption: The RACC for yogurt has gone from 225 g to 170 g. In this example, the % Daily Value for calcium has gone from 20% (which is considered an “Excellent Source of Calcium”) to 10% (which is considered a “Good Source of Calcium”).Nutrient Content Claims

Changes in the RACC may impact whether a product is eligible to make nutrient content claims and health claims. Be sure to evaluate your entire package’s labeling when updating labels with RACC changes.

Keep in mind that nutrient content claims are calculated based on the serving size, not the total package. When making a nutrient content claim or health claim on packages that have a dual-column label, the claim must be followed by a statement that references the basis on which the claim is made. Example: “low sodium” (Contains less than 140 mg of sodium per serving)

However, the statement is not required for products when the nutrient content claim meets the criteria for both per serving and per container.


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