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As Prepared Column Nutrition Facts Label

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.

Allowed for foods prepared before eating § 101.9(e)

On the package

A canister of instant oats with directions to add milk, and its two column panelThe directions say to add 1 cup of milk. The panel may add a column for the oats as prepared, as prominent as the dry column.OATSDirections1 cup 2% milkStir in, heat 2 min
40 g
Dry oats, one serving
+ 1 cup milk
From the directions
Optional
A column for the oats as prepared
Why this format

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.

§ 101.9(h)(4)

An invented product, for illustration.

The label, part by part

Tap a part.

Nutrition Facts

About 13 servings per container

Serving size1/2 cup dry (40g)

Dry, and with milk

CaloriesPer 1/2 cup dry150With 1 cup 2% milk270

Equal prominence for both

% DV*% DV*

Total Fat2.5g3%8g10%

Saturated Fat0.5g3%3.5g18%

Trans Fat0g0g

Cholesterol0mg0%20mg7%

Sodium0mg0%115mg5%

Total Carb.27g10%39g14%

Dietary Fiber4g15%4g15%

Total Sugars0g13g

Incl. Added Sugars0g0%0g0%

Protein5g13g

Two columns too

Vitamin D0mcg0%2.9mcg15%

Calcium20mg2%310mg25%

Iron1.7mg10%1.7mg10%

Potassium140mg4%490mg10%

*The % Daily Value (DV) tells you how much a nutrient in a serving of food contributes to a daily diet. 2,000 calories a day is used for general nutrition advice.

An 18 oz canister of instant oats. Invented values, rounded the FDA way.

FDA’s sample

FDA sample label: Two forms of the same food, from 21 CFR 101.9(e)(5)
FDA sample label: Two forms of the same food. Printed in 21 CFR 101.9(e)(5), published at 83 FR 65493. Cropped and resized from FDA’s graphic. Values are illustrative. Download FDA’s original (PNG)

Whole panel

Rules for the panel as a whole: space and bold type.

As prepared column panel space: Wider than the standard vertical panel, about one column more.+1 column
One column wider

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

  • “Total carb.” and “Incl.” are allowed on dual column panels

    Short names

    “Total carb.” and “Incl.” are allowed on dual column panels

    Rule text § 101.9(j)(13)(ii)(B)

  • Both columns Equal prominence

    Both columns

    Equal prominence

    Rule text § 101.9(e)

In words

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

Heading

The title at the top of the panel.

  • “Nutrition Facts” heading No smaller than any other type, except the calorie number

    “Nutrition Facts” heading

    No smaller than any other type, except the calorie number

    Rule text § 101.9(d)(2)

Serving

How many servings the package holds, and how big one is.

  • 10 pt

    Servings per container

    10 pt or larger

    Rule text § 101.9(d)(3)(i)

  • 10 pt, bold

    Serving size line

    10 pt or larger, bold

    Rule text § 101.9(d)(3)(ii)

  • Column heading examples “Per 1/4 cup mix” and “Per prepared portion”

    Column heading examples

    “Per 1/4 cup mix” and “Per prepared portion”

    Rule text § 101.9(e)(1)

Calories

The calories in one serving.

Dry, and with milk § 101.9(e)(1)

  • 16 pt, bold

    “Calories”

    16 pt or larger, bold

    Rule text § 101.9(d)(1)(iii)

  • 22 pt, bold

    Calorie number

    22 pt or larger, bold

    Rule text § 101.9(d)(1)(iii)

  • “Amount per serving” Not required on a dual column panel

    “Amount per serving”

    Not required on a dual column panel

    Rule text § 101.9(d)(4)

  • Column headings Accurately describe the amount each column covers

    Column headings

    Accurately describe the amount each column covers

    Rule text § 101.9(e)(1)

  • 6 pt

    Column heading type

    6 pt or larger

    From FDA’s sample § 101.9(e)(1)

Nutrients

Fat, cholesterol, sodium, carbohydrate and protein, with the %DV where there is one.

Equal prominence for both § 101.9(e)

  • 8 pt

    Nutrient, vitamin and mineral rows

    8 pt or larger

    Rule text § 101.9(d)(1)(iii)

  • 6 pt

    The “% DV*” headings and the footnote

    6 pt or larger

    Rule text § 101.9(d)(1)(iii)

  • Columns Amounts and %DV in two columns, split by vertical lines

    Columns

    Amounts and %DV in two columns, split by vertical lines

    Rule text § 101.9(e)(3)

Vitamins and minerals

Vitamin D, calcium, iron and potassium, plus any others you list.

Two columns too § 101.9(e)(4)

  • 8 pt

    Nutrient, vitamin and mineral rows

    8 pt or larger

    Rule text § 101.9(d)(1)(iii)

  • Vitamins and minerals Listed vertically, not side by side

    Vitamins and minerals

    Listed vertically, not side by side

    Rule text § 101.9(e)(4)

Footnote

The note at the bottom that says what %DV means.

  • 6 pt

    The “% DV*” headings and the footnote

    6 pt or larger

    Rule text § 101.9(d)(1)(iii)

?

Rule text

From FDA’s sample

BetterMenu’s choice

Do I need this?

Is it prepared before eating, or eaten with another food?

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

Some foods need no panel at all (§ 101.9(j))

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. Open Studio

In detail

When does the as prepared column stand in for a per-package column?2 examples

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.

§ 101.9(b)(12)(i)(C) Find your reference amount
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.

§ 101.9(b)(12)(i)(C)
Common mistakes2 mistakes
  • Wrong: Adding the column without printing what to add and how to prepare it.

    Wrong: Adding the column without printing what to add and how to prepare it.

    Right: Print the directions on the label.

    Right: Print the directions on the label.

    § 101.9(h)(4)
  • Wrong: Setting the as prepared column smaller than the as packaged one. 150 270

    Wrong: Setting the as prepared column smaller than the as packaged one.

    Right: Give both columns equal prominence. 150 270

    Right: Give both columns equal prominence.

    § 101.9(e)
Rule text and sources5 quotes
“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

Related formats

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.

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.

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.

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.

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