Avoid relabelling, rejected orders, and buyer pushback by getting US food labelling right from the start. This guide explains exactly what FDA requires for packaged microgreens, how allergen rules work, and what changes the moment you sell wholesale.
Start With One Question: How Are You Selling?
In the United States, labelling requirements are triggered less by what you grow and more by how you sell it.
If microgreens are packaged before sale — clamshells, bags, punnets, or prepared live trays — they are generally treated as packaged food under FDA labelling rules. This applies whether you sell at a farmers market, direct to customers, or into wholesale.
Some direct-to-consumer situations may qualify for limited exemptions depending on state law, but the moment you sell to another food business, most flexibility disappears. Restaurants, retailers, and distributors expect fully compliant labels, even if small-scale exemptions technically exist.
What Must Appear on Packaged Microgreens Labels
For FDA-regulated packaged foods, including most microgreens, several elements are typically required once wholesale enters the picture.
Statement of Identity
The label must clearly state what the product is. “Broccoli Microgreens,” “Pea Shoots,” or “Microgreen Mix” are clear. Creative brand names can appear, but they cannot replace a clear food identity.
Net Weight
Net weight must be declared in both US customary units (ounces or pounds) and metric units (grams or kilograms). Missing metric weight is one of the most common reasons wholesale labels are rejected.
Name and Address of the Responsible Business
The label must identify the responsible business, including location. This establishes accountability if issues arise. Wholesale buyers rely on this for traceability and liability clarity.
Ingredients List (When Required)
Single-ingredient products like “Radish Microgreens” do not require an ingredients list. The moment you sell blends or add oils, seeds, or garnishes, an ingredients list becomes mandatory.
Nutrition Facts
Many small producers qualify for exemptions when selling directly to consumers. Those exemptions often do not hold once wholesale begins. Retailers frequently require Nutrition Facts panels regardless of exemption status for shelf consistency.
Storage Instructions
While not always strictly mandatory, “Keep Refrigerated” is expected in practice. It signals understanding of cold chain control and shelf-life risk.
Allergens in the United States
Federal law recognises nine major allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame.
If any of these are present as ingredients, they must be clearly declared. This is particularly relevant for microgreens blends that include sesame.
Unlike the EU, the US allergen list is narrower. However, enforcement is strict. Wholesale buyers often review allergen statements carefully because allergen failures lead directly to recalls.
What Changes When You Sell Wholesale
Wholesale is the turning point for labelling.
When you sell to another food business, that buyer becomes responsible for reselling compliant food. Because of this, wholesale buyers typically expect:
- Full FDA-compliant labels
- Consistent product naming across invoices and labels
- Clear allergen declarations
- Lot or harvest codes
- Storage instructions
Even if an exemption technically exists, wholesale buyers often decline to rely on it.
Lot Codes and Traceability
Wholesale packs should include some form of lot or harvest identification. If you use outer cartons, those cartons should identify what is inside, who produced it, and the batch reference.
This is not bureaucratic overreach. It allows rapid response if a recall or complaint arises.
Who Enforces Labelling Rules
Federal food labelling law falls under the FDA. In practice, enforcement and inspections are typically handled by state departments of agriculture and local health authorities.
While the law is federal, interpretation often occurs at state level. Checking labels with your state or county authority before scaling wholesale sales can prevent expensive redesigns.
A Label Structure That Scales
A clean, scalable label layout usually includes:
- Main display panel: product name and net weight
- Information panel: ingredients (if required), allergen declaration, business name and address, storage instructions
- Nutrition Facts panel when required
- Lot or harvest code for traceability
Consistency matters more than design.
Where Things Commonly Go Wrong
- Assuming market exemptions apply to wholesale
- Forgetting metric weight
- Missing sesame allergen declaration
- Delaying Nutrition Facts until buyers demand them
- Inconsistent product naming
A Practical Approach to Compliance
Build labels that already meet wholesale expectations, even if you are currently selling direct. Designing once and scaling forward avoids reprints, rejected orders, and uncomfortable compliance conversations.
Clear identity, accurate weight, responsible business details, allergen clarity, and storage guidance cover most compliance risk.
References and Official Guidance (USA)
- Food and Drug Administration — Food Labeling & Nutrition, Allergen Labeling, Small Business Assistance
- FDA Food Labeling Guide
- FDA Guidance for Industry: Questions and Answers Regarding Food Allergens
- FDA Nutrition Labeling Manual
- U.S. Department of Agriculture — Jurisdiction Clarification
- State Departments of Agriculture
- County and City Health Departments
- Small Business Development Centers (SBDC)
- Cooperative Extension Services