# As Prepared Column Nutrition Facts Label

One column for the food as sold and one for the food as prepared or eaten with another food, such as cereal with milk.

You may add a column for the food as prepared, or as eaten with another food, beside the column as packaged. The label must then give the other ingredients and the directions.

**URL:** https://bettermenu.live/tools/label-formats/dual-column-as-prepared/
**Provider:** BetterMenu (https://bettermenu.live)
**Rule:** Allowed for foods prepared before eating. [21 CFR 101.9(e)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)), [21 CFR 101.9(h)(4)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(h)(4))
**Source:** FDA 21 CFR 101.9, eCFR as of 2026-02-12
**In BetterMenu Studio:** Studio works out the per-serving and per-package numbers from your recipe today. It exports the standard vertical panel. As prepared column export is not available yet. Studio gives the numbers for the food as packaged, and for the prepared food when you save it as its own recipe, and your designer sets both in the as prepared layout.

These pages are for conventional foods and drinks, not dietary supplements or medical foods.

## Do I need this?

Allowed if the food is prepared before eating, or eaten with another food.

The page asks one question at a time, only while the answer can still change the result:

- Is it prepared before eating, or eaten with another food? (Yes / No)

Decision rules, from the same logic as the page:

- If preparation is “Yes”, then: You may use this format. The label must give the directions.
- If preparation is “No”, then: Not this format. Use Standard vertical.

Next steps once it applies: Write the directions and what to add, and print them on the label. Send your designer the as prepared sample and the spec below.

## Worked example: When does the as prepared column stand in for a per-package column?

A cup of plain instant oatmeal holds 90 g of dry oats. The reference amount for plain dry hot cereal is 40 g. 90 ÷ 40 × 100 = 225%. That is between 200% and 300%, so a per-package column is required, unless the label gives an as prepared column. With the as prepared column, the per-package column is not required. ([21 CFR 101.9(b)(12)(i)(C)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(b)(12)(i)(C))) Find your reference amount: https://bettermenu.live/tools/racc/

## How it differs from standard vertical

A column for the food as prepared sits beside the column as packaged. Both columns get equal prominence. The label names what to add and how to prepare it.

1. Equal prominence for both ([21 CFR 101.9(e)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)))
2. As prepared column ([21 CFR 101.9(h)(4)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(h)(4)))

## It can stand in for a per-package column

A package that holds 200% to 300% of its reference amount needs no per-package column when the label gives an as prepared column.

Sources: [21 CFR 101.9(b)(12)(i)(C)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(b)(12)(i)(C))

## FDA sample label

- Two forms of the same food: printed in [21 CFR 101.9(e)(5)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)(5)), published at 83 FR 65493 (https://www.federalregister.gov/documents/2018/12/21/2018-27431/food-labeling-revision-of-the-nutrition-and-supplement-facts-labels-technical-amendments). The values on FDA's sample are illustrative.

## For your designer

Space: Wider than the standard vertical panel, about one column more.

| Part | Value | Source | Citation |
| --- | --- | --- | --- |
| Nutrient, vitamin and mineral rows | 8 pt or larger | Rule text | [21 CFR 101.9(d)(1)(iii)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(d)(1)(iii)) |
| “Calories” | 16 pt or larger, bold | Rule text | [21 CFR 101.9(d)(1)(iii)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(d)(1)(iii)) |
| Calorie number | 22 pt or larger, bold | Rule text | [21 CFR 101.9(d)(1)(iii)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(d)(1)(iii)) |
| Servings per container | 10 pt or larger | Rule text | [21 CFR 101.9(d)(3)(i)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(d)(3)(i)) |
| Serving size line | 10 pt or larger, bold | Rule text | [21 CFR 101.9(d)(3)(ii)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(d)(3)(ii)) |
| The “% DV*” headings and the footnote | 6 pt or larger | Rule text | [21 CFR 101.9(d)(1)(iii)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(d)(1)(iii)) |
| “Nutrition Facts” heading | No smaller than any other type, except the calorie number | Rule text | [21 CFR 101.9(d)(2)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(d)(2)) |
| Columns | Amounts and %DV in two columns, split by vertical lines | Rule text | [21 CFR 101.9(e)(3)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)(3)) |
| Vitamins and minerals | Listed vertically, not side by side | Rule text | [21 CFR 101.9(e)(4)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)(4)) |
| “Amount per serving” | Not required on a dual column panel | Rule text | [21 CFR 101.9(d)(4)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(d)(4)) |
| Short names | “Total carb.” and “Incl.” are allowed on dual column panels | Rule text | [21 CFR 101.9(j)(13)(ii)(B)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(j)(13)(ii)(B)) |
| Column headings | Accurately describe the amount each column covers | Rule text | [21 CFR 101.9(e)(1)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)(1)) |
| Column heading type | 6 pt or larger | From FDA’s sample | [21 CFR 101.9(e)(1)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)(1)) |
| Both columns | Equal prominence | Rule text | [21 CFR 101.9(e)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)) |
| Column heading examples | “Per 1/4 cup mix” and “Per prepared portion” | Rule text | [21 CFR 101.9(e)(1)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)(1)) |

“From FDA’s sample” means the value was measured from FDA’s sample label, not stated in the rule text. “BetterMenu’s choice” is our own value where the rule text is silent.

- Download FDA’s sample label, Two forms of the same food: https://bettermenu.live/tools/label-formats/fda/er21de18.010.png

## Common mistakes

- Adding the column without printing what to add and how to prepare it. ([21 CFR 101.9(h)(4)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(h)(4)))
- Setting the as prepared column smaller than the as packaged one. Both get equal prominence. ([21 CFR 101.9(e)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(e)))

## Example: An 18 oz canister of instant oats

The directions say to stir 1/2 cup of oats into 1 cup of 2% milk and heat it. The label may show a column per 1/2 cup dry and a column made with the milk, with equal prominence. ([21 CFR 101.9(h)(4)](https://www.ecfr.gov/current/title-21/section-101.9#p-101.9(h)(4))) An invented product, for illustration.

## Related formats

- [Dual column](https://bettermenu.live/tools/label-formats/dual-column/)
- [Per 100 g column](https://bettermenu.live/tools/label-formats/per-100g-column/)
- [Standard vertical](https://bettermenu.live/tools/label-formats/standard-vertical/)

## Rule text

> “Nutrition information may be presented for two or more forms of the same food (e.g., both “as purchased” and “as prepared”) or for common combinations of food as provided for in paragraph (h)(4) of this section, for different units (e.g., slices of bread or per 100 grams) as provided for in paragraph (b) of this section, or for two or more groups for which RDIs are established (e.g., both infants through 12 months of age and children 1 through 3 years of age) as shown in paragraph (e)(5) of this section.”
> 21 CFR 101.9(e), eCFR as of 2026-02-12

> “When such dual labeling is provided, equal prominence shall be given to both sets of values.”
> 21 CFR 101.9(e), eCFR as of 2026-02-12

> “If a food is commonly combined with other ingredients or is cooked or otherwise prepared before eating, and directions for such combination or preparations are provided, another column of figures may be used to declare nutrition information on the basis of the food as consumed in the format required in paragraph (e) of this section” …
> 21 CFR 101.9(h)(4), eCFR as of 2026-02-12

> … “Provided, that, the type and quantity of the other ingredients to be added to the product by the user and the specific method of cooking and other preparation shall be specified prominently on the label.”
> 21 CFR 101.9(h)(4), eCFR as of 2026-02-12

> “This provision does not apply to products that require further preparation and provide an additional column of nutrition information under paragraph (e) of this section, to products that are commonly consumed in combination with another food and provide an additional column of nutrition information under paragraph (e) of this section, to products that provide an additional column of nutrition information for two or more groups for which RDIs are established (e.g., both infants and children less than 4 years of age), to popcorn products that provide an additional column of nutrition information per 1 cup popped popcorn, or to varied-weight products covered under paragraph (b)(8)(iii) of this section.”
> 21 CFR 101.9(b)(12)(i)(C), eCFR as of 2026-02-12

## Frequently asked questions

### When can I add an as prepared column?

When the food is cooked or otherwise prepared before eating, or commonly eaten with another food, and the label gives the directions.

Sources: 21 CFR 101.9(h)(4), 21 CFR 101.9(e)

### What must the label say with an as prepared column?

The type and amount of each other ingredient, and how to cook or prepare the food. These must be prominent on the label.

Sources: 21 CFR 101.9(h)(4)

### Does an as prepared column replace a per-package column?

It can. A package that holds 200% to 300% of its reference amount needs no per-package column when it gives an as prepared column.

Sources: 21 CFR 101.9(b)(12)(i)(C)

### How do I work out the percentage?

Divide the amount in one package, or one unit, by its reference amount and multiply by 100. An 850 mL bottle of iced tea, with the 360 mL reference amount for sweetened tea in 21 CFR 101.12(b), is 850 ÷ 360 × 100 = 236%. That is between 200% and 300%, so it needs the second column.

Sources: 21 CFR 101.9(b)(12)(i)

## Machine-readable data

This page as JSON: https://bettermenu.live/tools/label-formats/dual-column-as-prepared/data.json
Every format: https://bettermenu.live/tools/label-formats/data.json