Hawaii Cottage Food Label Requirements

What the Label Must Include

Every homemade food product sold under Hawaii's HAR Title 11, Chapter 50 exemption must carry a label with six mandatory fields. Missing any one of them puts you out of compliance, and the rules apply whether you are selling at a farmers market, shipping within Hawaii, or wholesaling to a permitted retailer.

The six required elements:

1. Common name of the food — "Lilikoi Jelly," "Macadamia Nut Brittle," not a brand name alone.
2. Business name and physical contact information — your registered business name plus a way to reach you (address, phone, or email).
3. Ingredient statement — every ingredient listed in descending order by weight, using common names.
4. Major allergen declaration — all nine allergens that apply to your product.
5. Net weight or volume — measured using a scale calibrated to USP/FDA standards.
6. DOH disclaimer — the exact state-mandated consumer advisory, printed in a minimum of 10-point font with high contrast against the label background.

The Nine Major Allergens

Under federal law (the FASTER Act, effective January 2023), food labels must declare nine major allergens: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, and sesame. Sesame was the most recent addition, and many older label templates do not include it.

You can declare allergens by listing them parenthetically in the ingredient statement — "tahini (sesame)" — or with a separate "Contains" statement below the ingredient list. Either format satisfies the requirement. What does not satisfy it: relying on a "may contain" statement alone when the allergen is an ingredient, or omitting an allergen that is part of the product's ingredients.

If your kitchen produces multiple products and cross-contact is a realistic possibility, you should also include a precautionary "Produced in a facility that also processes [allergen]" statement — but this is voluntary, not a substitute for the mandatory "Contains" line.

The DOH Disclaimer

The mandatory disclaimer is a consumer advisory informing buyers that the product was made in an uninspected home kitchen. The text must appear on the label in at least 10-point font and be clearly legible against the background color.

This is not optional, and it is not something you can paraphrase. The DOH Food Safety Branch specifies the exact wording. Products missing the disclaimer — or printing it in type too small to read — are out of compliance even if everything else on the label is correct.

Label Design Practicalities

Most home food operators use adhesive labels printed on a desktop inkjet or laser printer. A few things to get right:

• Font size matters. The 10-point minimum for the DOH disclaimer is measured in standard typographic points. Print a test label and hold a ruler to it — word processors sometimes render point sizes differently depending on the font.
• Contrast matters. Dark text on a light background or light text on a dark background. Decorative labels with low-contrast text (pastel on pastel, or text overlapping a photo) will fail a compliance check even at the right point size.
• Weight accuracy matters. Use a calibrated digital kitchen scale. A $30 to $50 scale with 0.1 oz or 1g precision is adequate for most cottage food products. Weigh the product — not the product plus packaging — and print the net weight on the label.

Wholesale and Farmers Market Label Rules

If you sell wholesale to a permitted retailer (a grocery store, cafe, or restaurant), the retailer must keep your original product label on-site and make it available to any customer who asks. This means your labels need to be durable enough to survive commercial handling — waterproof adhesive labels hold up better than paper tags stapled to bags.

At farmers markets, your label serves double duty: it is both your compliance document and your sales material. Pre-packaged items with sealed labels do not themselves require an additional DOH permit, although an event organizer or local sanitarian may require a Special Event Permit. But if you slice, serve, or open-plate products at your booth — even to offer samples — that activity is classified as on-site food preparation and triggers a Special Event Permit requirement ($25 fee, 10 working days advance notice, plus a temporary handwashing station at the booth).

Getting the Labels Right Before Your First Sale

The Hawaii Cottage Food & Home Food Business Guide includes the complete label specification with the exact DOH disclaimer text, a layout reference showing where each mandatory field should appear, and the allergen declaration format. Label design is Step 6 in the startup sequence — after recipe validation, food safety training, business registration, GET license, and county zoning clearance. Getting the order right prevents wasted label inventory if a recipe change is needed earlier in the process.

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