Utah Cottage Food Label Requirements: Every Element Your Label Needs
UDAF rejects cottage food applications most often over labeling — not recipes, not kitchen cleanliness. A missing allergen declaration or an undersized disclaimer sends your entire application back, adding weeks to your timeline. Here's exactly what every label needs under Rule R70-560.
Required Label Elements
Every product you sell under Utah's Traditional Cottage Food Program must display a label with these six elements:
1. Product common name — the standard name of the food (e.g., "Chocolate Chip Cookies," "Strawberry Jam"). Use the name a reasonable consumer would recognize.
2. Ingredients list in descending order by weight — not by volume. If your recipe uses cups and tablespoons, convert to ounces or grams for the label. Compound ingredients (like chocolate chips) must include their sub-ingredients. List tree nuts by their specific common name (almonds, pecans, walnuts — not just "tree nuts").
3. Allergen declarations — covering all nine major FDA food allergens: milk, eggs, wheat, soy, peanuts, tree nuts (by name), fish, shellfish, and sesame. Use a "Contains:" statement or bold the allergens within the ingredients list. If your product is made in a kitchen that processes allergens, a cross-contact advisory ("Made in a kitchen that also processes wheat and tree nuts") is strongly recommended.
4. Net quantity of contents — displayed in both US customary (oz, lb) and metric (g, kg) units. For baked goods sold by count (e.g., "6 cookies"), you still need the net weight.
5. Manufacturer's name, physical address, and telephone number — your legal name (or registered business name), street address (P.O. boxes don't count), and a working phone number. This is the traceability link if a product needs to be recalled.
6. "Home Produced" statement — this must appear in bold, conspicuous, 12-point font minimum on the principal display panel. Not the back of the label, not in fine print — the front, where a customer sees it first. This is the single most common correction UDAF requests.
7. Batch identification (internal record) — while not displayed on the customer-facing label, your internal records must link every label to a production batch (date, time, quantity). UDAF's 14-day sample retention rule means you need to trace any product back to its batch.
Cottage Food vs. Homemade Food Act Labels
If you're operating under the Homemade Food Act (HB 181) instead of the Traditional Cottage Food Program, the labeling requirements are different:
| Element | Cottage Food (R70-560) | Homemade Food Act (HB 181) |
|---|---|---|
| Ingredients list | Descending by weight, 21 CFR 101 | Descending by weight |
| Allergen declaration | Nine FDA allergens | Common allergens |
| Net weight | US customary + metric | Not specified |
| Manufacturer info | Name, address, phone | Name and address |
| Mandatory statement | "Home Produced" (bold, 12pt) | "Not for Resale – Processed and prepared without the benefit of state or local inspection" |
| FDA compliance | 21 CFR Part 101 | Not required |
The Homemade Food Act's disclosure is longer but doesn't have the same font-size mandate. Cottage food labels must meet the full FDA labeling standard under 21 CFR Part 101 because UDAF inspectors enforce federal standards at the state level.
Common Labeling Mistakes
"Home Produced" too small or on the back: It must be on the principal display panel in bold, 12-point font minimum. If UDAF has to look for it, they'll send your application back.
Ingredients listed by volume: UDAF requires weight-based ordering. "1 cup flour" is meaningless on a food label. Convert everything to ounces or grams.
Missing sub-ingredients: If you use chocolate chips, the label must list the chocolate chips' own ingredients (sugar, chocolate liquor, cocoa butter, soy lecithin, etc.). Same for pre-made pie crusts, spice blends, or any multi-component ingredient.
Generic tree nut listing: "Contains: tree nuts" isn't sufficient. You must name the specific nut — almonds, cashews, pecans, walnuts, etc.
Missing metric units: US customary alone doesn't meet FDA labeling requirements. Include both: "Net Wt. 8 oz (227g)."
No phone number: Name and address alone aren't enough under R70-560. A working telephone number is mandatory.
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Formatting Your Labels
UDAF reviews label mock-ups as part of your application packet. Submit them in the format you'll actually use — printed on the same material, at the same size. If you're using adhesive labels from a home printer, that's fine, but the mock-up should reflect what the customer will see.
For readability, the FDA recommends:
- Minimum 6-point type for most label text
- Minimum 12-point bold for the "Home Produced" statement
- Contrasting text and background colors (black text on white or light background)
- Ingredient list and allergen statement on the information panel (side or back), "Home Produced" on the principal display panel (front)
Label Changes After Registration
If you modify a recipe, change an ingredient supplier (which could change sub-ingredients), or add a new product, UDAF requires updated label mock-ups before you can sell the modified product. This isn't optional — selling a product with inaccurate label information is a regulatory violation, and UDAF can suspend your registration.
Keep your approved label files organized by product and version. When you submit an update, reference the original approval so UDAF's plan review team can compare changes.
For downloadable label templates pre-configured with all required elements for both pathways, our Utah Cottage Food & Home Food Business Guide includes ready-to-customize formats that meet UDAF and FDA standards.
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