Last verified 16 Sep 2026 · Sources
If you’re asking this, you’ve probably got label art laid out and aren’t sure whether the ingredient list goes on the front or the side. Short answer: the front is the principal display panel (PDP). It must carry the statement of identity and net quantity of contents, prominently, per 21 CFR 101.1 and 101.3. The panel immediately to its right is the information panel, where the ingredient list, the manufacturer’s name and address, and (if not on the PDP) the Nutrition Facts label belong, per 21 CFR 101.2. Both panels have their own area math and placement rules, and getting the assignment wrong is a common reason a co-packer bounces a label back.
| Quick facts | PDP & information panel |
|---|---|
| Regulation | 21 CFR 101.1, 101.2, 101.3, 101.5 |
| Applies to | Any food label choosing what goes on the front vs. side/back panel |
| Key numbers | PDP area: rectangular = h×w; cylinder = 40% of h×circumference; other = 40% of surface |
The rule
21 CFR 101.1 defines the principal display panel as “the part of a label that is most likely to be displayed, presented, shown, or examined under customary conditions of display for retail sale.” It must be “large enough to accommodate all the mandatory label information required to be placed thereon by this part with clarity and conspicuousness and without obscuring design, vignettes, or crowding.” 21 CFR 101.3(a) then requires the PDP “bear as one of its principal features a statement of the identity of the commodity,” in bold type, per 101.3(d), “in a size reasonably related to the most prominent printed matter on such panel,” parallel to the package’s base.
21 CFR 101.2(a) defines the information panel as “that part of the label immediately contiguous and to the right of the principal display panel,” with exceptions for unusable space, an alternate panel readily seen by the consumer, or a case where the PDP itself is the top of the package. Under 101.2(b), the ingredient statement (101.4), the name and place of business (101.5), and nutrition information (101.9) must each appear on the PDP or the information panel (not forced onto one specific panel, just onto one of those two), and 101.2(e) requires that whichever lands on the information panel appear “in one place without other intervening material.” That clause is the one most often missed: you can’t put the ingredient list on the information panel with a recipe or marketing blurb wedged into the middle of it.
21 CFR 101.5(a) separately requires your label to “specify conspicuously the name and place of business of the manufacturer, packer, or distributor,” including street address, city, state, and ZIP code, with one narrow exception in 101.5(d): “the street address may be omitted if it is shown in a current city directory or telephone directory.” Whether an online listing service satisfies that “current city or telephone directory” language is a question for a food-labeling attorney, not something to assume either way.
The numbers
PDP area is calculated differently by container shape, per 21 CFR 101.1:
| Container shape | PDP area formula |
|---|---|
| Rectangular package | Height × width of that side |
| Cylindrical container | 40% of (height × circumference) |
| Any other shape | 40% of total surface area, excluding tops, bottoms, flanges, shoulders, and necks |
For a cylinder, the required information must sit “within that 40 percent of the circumference which is most likely to be displayed” at retail, not just anywhere on the wrap. Type size on the information panel generally must be at least one-sixteenth inch in height under 101.2(c), which lists several exceptions to that minimum (for example small packages under 101.2(c)(1)–(5) and soft-drink bottles) without needing every exception spelled out here.
Here’s what belongs where:
| Element | Governing rule | PDP or information panel |
|---|---|---|
| Statement of identity | 101.3 | PDP only |
| Net quantity of contents | 101.7 | PDP only, lower 30% |
| Ingredient statement | 101.4 | PDP or information panel |
| Name and place of business | 101.5 | PDP or information panel |
| Nutrition Facts | 101.9 | PDP or information panel |
| Allergen “Contains” statement | 101.4 (FALCPA) | Immediately after or adjacent to ingredient list |
On the label
Say you bottle hot sauce in a 12 fl oz glass jar, a cylinder. Its PDP area is 40% of height times circumference: say roughly 14 square inches. On that panel: your brand name and “Hot Sauce” (statement of identity) in bold, sized to the brand name’s prominence, plus net quantity (“12 FL OZ (355 mL)”) in the bottom 30%. The panel immediately right, wrapping the jar, is the information panel: ingredient list, “Contains” line if applicable, your business name and address, and Nutrition Facts, all together with no recipe copy or brand-story text breaking up the block. Dropping Nutrition Facts onto the back “because that’s how labels look” is fine only if the back genuinely functions as the information panel.
Mistakes we see
- Sandwiching a slogan between the ingredient list and “Contains” statement. This breaks the “no intervening material” rule in 101.2(e).
- Sizing the statement of identity smaller than the brand’s decorative logo type, so it isn’t “reasonably related” to the panel’s most prominent print, per 101.3(d).
- Calculating PDP area as the whole front label instead of the shape-specific formula, inflating or shrinking the required panel.
- Omitting the street address without confirming your business is listed in a current directory under 101.5(d).
- Assuming Nutrition Facts must go on the “back”. The rule only requires the PDP or the information panel.
Related rules
Once panel assignment is settled, type size and placement covers the point sizes that make each element legible, and net quantity statement covers the lower-30%-of-PDP rule. Ingredient statement covers what has to be listed once you’ve picked its panel.
Build it right the first time
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FAQ
Does the Nutrition Facts label have to go on the information panel?
No. It can go on the information panel or the principal display panel. 21 CFR 101.2(b) just requires it appear on one of the two, in one place, without other material breaking it up.
Can I skip my street address on the label?
21 CFR 101.5(d) allows omitting the street address only if it's shown in a current city or telephone directory; talk to a food-labeling attorney if you're unsure your listing qualifies.
What if my package is a weird shape, like a pouch or a jar with a shoulder?
For anything that isn't a simple rectangle or cylinder, 101.1 defines the PDP as 40% of the total surface area of the container, excluding tops, bottoms, flanges, shoulders, and necks.
Does the statement of identity have to be the biggest text on the front?
Not necessarily the biggest, but 21 CFR 101.3(d) requires it be in a size reasonably related to the most prominent printed matter on that panel, in bold type, parallel to the base.
Can the ingredient list go on the front of the package instead of the side?
Yes. 101.2(b) requires it on the PDP or information panel, so the front panel works as long as it doesn't crowd out the statement of identity.
Related rules
Type size and placement, Ingredient statement (descending order), Net quantity statement. See the full all labeling rules.