Last verified 16 Sep 2026 · Sources
Say your small package qualifies for the small-package tabular layout and holds between 200% and 300% of its Reference Amount Customarily Consumed (RACC), the FDA’s reference amount for your type of food. It can still show both a per-serving and a per-container column in tabular format. That’s true even though 21 CFR 101.9(b)(12)(i)(A) says packages that can use tabular don’t have to add that second column at all.
| Quick facts | Tabular dual column |
|---|---|
| Governing rule | 21 CFR 101.9(b)(12)(i)(A), 101.9(j)(13)(ii)(A)(1) |
| Allowed when | Package qualifies for small-package tabular (under 12 sq in, or up to 40 sq in when a vertical column won't fit) and holds 200–300% of the RACC |
| Required when | Never required. Tabular-eligible packages are exempt from the mandatory dual column. |
| Package area | 40 sq in or less |
| In the NutriLabels builder | Expert service only (not in the builder) |
When can you use it?
The range of 200% to 300% of RACC comes from 21 CFR 101.9(b)(12)(i). That rule normally requires an extra per-container column next to the per-serving column for individually packaged products in that range. Separately, 21 CFR 101.9(j)(13)(ii)(A) lets a package use a tabular layout if it has less than 12 sq in of total surface area available to bear labeling. A package of 40 sq in or less qualifies too, if its shape or size can’t fit a standard vertical column.
When your package fits both at once (small enough for tabular, and sized between 200% and 300% of RACC), you can still choose to build the tabular panel with two columns. Per-serving and per-container values then sit side by side in the tabular grid, instead of showing only one column.
When do you have to use it?
You never have to. There’s a specific exception in 21 CFR 101.9(b)(12)(i)(A). It says the required dual column in (b)(12)(i) “does not apply to” products that can use a tabular layout under 101.9(j)(13)(ii)(A)(1) or a linear layout under (j)(13)(ii)(A)(2).
So once your package qualifies for tabular because of its small size, the dual-column rule that would otherwise apply at 200% to 300% of RACC no longer covers it. A single-column tabular panel, showing only per-serving values, meets the rule on its own. Adding the second column becomes a business choice about how much to show on a small label, not a compliance requirement. The real question is whether your shoppers gain from seeing per-container totals on a package that size. Once the exemption applies, the rule itself takes no side.
What changes on the panel?
The panel keeps the row-and-column tabular layout allowed under 101.9(j)(13)(ii), instead of the standard single vertical column. Nutrients run across rows, with their amounts and % Daily Value in the cells next to them instead of stacked top to bottom.
Adding the optional second column means each nutrient row has two value cells. One is for the per-serving amount and one is for the per-container amount, with column headers that say clearly which is which.
The abbreviations allowed for small tabular packages under 101.9(j)(13)(ii)(B) (“Serv size,” “Sat fat,” “Cholest,” “Total carb,” and similar) still apply. The footnote may still be left off, or shown in its short “% DV = % Daily Value” form, under the same small-package rule. The required nutrients, rounding and order don’t change between the one-column and two-column versions. The only difference is whether a total for the whole container sits next to the per-serving value.
Mistakes to watch for
- Thinking a package between 200% and 300% of RACC automatically needs two columns, without checking whether it can use tabular and is therefore exempt.
- Adding the second column but forgetting to update the column headers so per-serving and per-container values are clearly told apart.
- Laying the two columns out the way a vertical dual-column panel does, instead of following the tabular layout once the panel has moved to rows and columns.
- Dropping the short footnote or nutrient-name abbreviations that come with the small-package tabular option. Or using them on a package that doesn’t actually qualify for tabular in the first place.
- Mixing up this optional tabular dual column with the required per-serving/per-container dual column for larger packages in the same RACC range that can’t use tabular.
Which products usually use it?
This optional layout shows up on small packages that hold two to three servings. Think snack-size chips or crackers bags, small trail mix and nuts pouches, and individually sized cookies or muffins packs. Small jerky bags sized close to the RACC threshold use it too.
Build your label
Deciding whether to add the optional second column to a tabular panel, and building it correctly if you do, is a judgment call. It’s best made with a person checking your package size and RACC math.
A per-container total next to the per-serving value tells a shopper what your whole pouch adds up to. Send us the recipe and we’ll build it for you. The done-for-you label service ($249) covers this format along with every other one your product qualifies for. Delivery is within 5 business days, with two revisions within 30 days of delivery. Order a done-for-you label.
For a product that doesn’t need this format, enter your recipe in the builder and then see your label. Your calories, the claims you qualify for and your allergen line are free, and no credit card is required. The rest of the numbers on your label stay hidden until you buy a Single Product ($29) or the Studio plan ($299 a year). A Single Product unlocks the rest of the numbers on your label in every FDA format your product qualifies for, with the ingredient statement and the allergen declaration. Start your label, or compare the other label formats.
Tabular dual column format FAQ
If my package qualifies for tabular format, do I ever need a second column?
Not as a requirement. Products that can use the small-package tabular layout in 101.9(j)(13)(ii)(A)(1) are exempt (21 CFR 101.9(b)(12)(i)(A)). They don't need the per-serving/per-container dual column that's otherwise required at 200% to 300% of the RACC.
Why would anyone add a second column if it's optional here?
You may still find it useful to show per-container totals next to per-serving values on a small package that holds two to three servings. The rule just doesn't force it once your package can use tabular.
What size packages does this apply to?
The small-package rule covers packages with less than 12 sq in of total surface area available to bear labeling (21 CFR 101.9(j)(13)(ii)(A)). It also covers packages of 40 sq in or less whose shape or size can't fit a standard vertical column. Those are the limits for using small-package tabular in the first place.
Does the RACC threshold still matter if tabular is optional?
Yes. On a larger package, 200% to 300% of RACC is the range that triggers the required dual column under 101.9(b)(12)(i). On a small package that can use tabular, the same math just tells you when the optional second column is worth a look. It's not required.
Can I see what a tabular dual-column panel looks like?
Yes. FDA provides a sample label for the tabular layout of the per-serving/per-container dual column (21 CFR 101.9(e)(6)(ii)).
Related formats
Tabular, Dual column: per serving / per container, Vertical with side-by-side micronutrients, Linear. See the full all label formats.