From Lab to Label: How Food Chemistry Ensures Accurate Food Labels

A New Regulatory Landscape for Nutrition Labels

In May 2025, the U.S. Food & Drug Administration (FDA) released a significant update to its Compliance Program 7321.005, titled "General Food Labeling Requirements and Labeling-Related Sample Analysis." This marked the first revision of the program since 2010 and places significantly stronger emphasis on the accuracy of Nutrition Facts Panels (NFPs), particularly for products making nutrient-content claims such as "low fat," "high in protein," or "good source of fiber."[1] 

The updated guidance authorizes FDA inspectors to conduct more frequent analytical testing to validate label accuracy. This shift underscores a critical takeaway for food manufacturers and private-label brands: ensure that your nutritional values are scientifically validated and defensible[3].

Why Accurate Nutritional Testing Is More Important Than Ever

Nutrition labeling is more than just a regulatory checkbox. It represents a brand's integrity and commitment to consumer transparency. Inaccurate or misleading nutritional declarations can have far-reaching consequences, ranging from warning letters and product recalls to class-action lawsuits and long-term reputational damage.

The revised FDA program outlines the expectation that labels must reflect verified analytical data. It’s no longer enough to rely solely on calculated values from nutrient databases or formulation spreadsheets. Declared values must fall within strict FDA tolerance limits, and validated lab results must support any nutrient-content claims made on the label. If your label states 8g of protein, consumers—and regulators—should be able to verify that claim in a lab.

From Lab to Label: The Chemistry Behind Compliance

At Mérieux NutriSciences, our nutritional testing services are designed to align with both FDA and international standards. Our chemistry laboratories employ validated methods to measure a full nutrient profile, including macronutrients such as protein, fat, carbohydrates, and dietary fiber.

• Protein is typically measured using Kjeldahl or Dumas methods.
  
  
• Fat content is assessed through Soxhlet extraction or acid hydrolysis, depending on the product matrix.
  
  
• Energy values are determined using Atwater factors or direct bomb calorimetry.
  
  
• Vitamins and minerals—including Vitamin D, calcium, iron, and potassium—are analyzed using techniques such as HPLC or ICP-OES.

We also quantify sugars (including added sugars) via high-performance liquid chromatography (HPLC), and measure sodium and cholesterol using techniques such as ion-selective electrodes and gas chromatography. All methods conform to AOAC, USP, and FDA protocols, ensuring scientific rigor and regulatory compliance.

What the FDA Is Looking For: Label vs. Lab Data

The FDA enforces specific tolerance thresholds to ensure label accuracy:

• Calories, total fat, sodium: must not exceed declared values by more than 20%.
  
  
• Vitamins and minerals: must meet at least 80% of the declared amount.
  
  
• Protein claims: must fall within ±20% of labeled values.

Small discrepancies between estimated and actual nutrient content can result in noncompliance. Brands that don’t validate their labels through proper analytical testing increase their risk of enforcement actions, ranging from warning letters to product seizures or recalls[2].

Common Pitfalls That Lead to Mislabeling

Even brands with robust quality assurance systems can fall victim to mislabeling errors. One common issue is when formulations are updated—either by changing ingredient sources or production methods—but the label is not updated to reflect those changes. This is especially common in outsourced or co-manufacturing environments, where visibility into process variations may be limited.

Ingredient variability can also affect nutrient values, particularly in naturally sourced components such as fruits, vegetables, or spices. When brands rely solely on database estimations rather than verified lab results, they risk applying inaccurate data to their labels. Inconsistent serving sizes, yield miscalculations, or lack of real-batch testing can further skew the numbers. These missteps not only open the door to FDA enforcement but can also mislead health-conscious consumers making dietary decisions based on your label.

A Scientific Approach to Label Creation

Creating an FDA-compliant label starts with testing your actual product, not just theoretical calculations. Once a formulation is finalized, representative samples are analyzed for nutrient content. Energy values are calculated, macronutrients measured, and micronutrients quantified using advanced instrumentation.

Test results are then interpreted in the context of serving size and labeling rules. This includes evaluating eligibility for nutrient-content claims such as “low fat” or “excellent source of iron.” The Nutrition Facts Panel is then built using validated data, ensuring regulatory alignment. Periodic retesting is recommended, especially following formulation updates, manufacturing changes, or regulatory revisions.

Global Standards: Meeting International Labeling Requirements

For brands with international reach, nutritional labeling must meet region-specific regulations. For example:

• EU: Regulation (EU) No 1169/2011 requires labeling of energy, fat, saturates, carbohydrates, sugars, protein, and salt.
  
  
• Canada: Labels must include 13 core nutrients in both English and French.
  
  
• Codex-compliant countries may have additional requirements for nutrient declarations.
  
  

Mérieux NutriSciences supports global compliance through region-specific test panels and regulatory consulting, helping brands maintain consistent and lawful labeling across multiple markets.

Case Example: Responding to a Labeling Crisis

A mid-sized snack company turned to Mérieux NutriSciences after receiving an FDA warning letter. The issue? Their “low sodium” claim was invalidated by lab tests showing sodium levels exceeded thresholds by over 30%. The root cause: a co-manufacturer had altered the formulation without notifying the brand, and the original label had been based on calculated—not tested—data.

We swiftly conducted analytical testing on new batches and collaborated with the client to update both the product and its label. We also helped prepare corrective documentation for the FDA. What could have spiraled into a costly recall and PR disaster was contained through timely scientific intervention.

Aligning With Consumer Expectations

Beyond compliance, today's consumers demand transparency. They expect clean labels, understandable ingredients, and honest nutrition information. Claims like “plant-based,” “no added sugar,” or “rich in fiber” are now considered baseline, not bonus.

But every claim must be supported with data. Reformulations aimed at improving nutritional profiles require lab validation to ensure continued accuracy. Nutritional chemistry testing bridges consumer expectations with regulatory standards, allowing brands to innovate responsibly.

Why Third-Party Testing Adds Strategic Value

Third-party nutritional testing provides more than regulatory insurance—it offers credibility, transparency, and consumer trust. At Mérieux NutriSciences, we partner with brands to provide customized nutritional testing tailored to product type, market, and label objectives. Our labs are ISO-accredited and staffed with experienced analytical chemists who use industry-recognized methodologies.

We deliver rapid turnaround, transparent reporting, and direct consultation on how to interpret and apply results. Whether you’re launching a new product or responding to a regulatory concern, third-party lab support ensures you make informed decisions rooted in science. It also strengthens your documentation portfolio in the event of FDA inquiries, supplier audits, or internal quality reviews.

Testing Is the Foundation of Trust

Accurate nutritional testing is the cornerstone of compliant labeling and brand credibility. With regulatory scrutiny intensifying and consumers demanding transparency, validated nutrient data is no longer optional—it’s essential.

Whether you’re launching a new product, revising a formulation, or preparing for inspection, nutritional chemistry must be an integral part of your workflow. Third-party lab services are not just a safeguard—they’re a statement of quality.

Partner With Mérieux NutriSciences

At Mérieux NutriSciences, we bridge the gap between lab and label by combining advanced food Chemistry Testing with comprehensive nutritional testing to deliver scientifically accurate and regulatorily compliant data. Our experts specialize in everything from macronutrient analysis to vitamin quantification, providing the essential insights brands need to create credible, compliant, and consumer-ready nutrition labels. Ensure your labels reflect science, not guesswork—partner with Mérieux NutriSciences, a trusted lab that delivers precise data you can rely on. Explore Our Nutritional Testing Services to learn more.

References

[1] U.S. Food and Drug Administration. (2025, May). Compliance program 7321.005: General food labeling requirements and labeling-related sample analysis (Version 1). https://www.fda.gov/media/71690/download 

[2] U.S. Food and Drug Administration. (n.d.). Food compliance programs. https://www.fda.gov/food/compliance-enforcement-food/food-compliance-programs

[3] U.S. Food and Drug Administration. (n.d.). Nutrition, food labeling, and critical foods. https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods