How to Write a Recipe for FDA Compliance: Ingredient Listing Rules

The Core Rule: Descending Order by Weight

Every ingredient on an FDA label must be listed in descending order of their weight in the final product. The ingredient present in the greatest amount comes first. This rule has no exceptions.

A common violation: listing water last when it's added in significant quantities during cooking.

Sub-Ingredient Declarations

When you use a multi-ingredient ingredient (like "canned tomatoes" or "mayonnaise"), you must declare its sub-ingredients in parentheses immediately following the ingredient name.

Example: Tomato Sauce (Tomatoes, Water, Sugar, Salt, Citric Acid)

Allergen Labeling (FALCPA)

Under the Food Allergen Labeling and Consumer Protection Act, the 9 major allergens must be declared:

• Milk, Eggs, Fish, Shellfish, Tree Nuts, Peanuts, Wheat, Soybeans
• NEW since 2023: Sesame

Allergens can be declared either within the ingredient list ("Contains: Milk, Wheat") or using the "Contains" statement after — but not both for the same allergen, as this creates ambiguity.

Flavors: Natural vs Artificial

The FDA allows flavors to be listed simply as "natural flavor" or "artificial flavor" without disclosing the specific flavoring compound. However, if a flavor is derived from an allergen (e.g., natural butter flavor derived from milk), the source must be declared.

Colors: Certified vs Exempt

Certified artificial colors (FD&C Red 40, Yellow 5, etc.) must be individually named. Exempt colors from natural sources (beet extract, annatto) can be listed as "coloring" or by common name.