21 CFR 101.2 defines the information panel of a packaged food label and establishes the rules for where mandatory labeling elements must be placed relative to the principal display panel (PDP). It is one of the foundational structural rules for food label layout.
What Is the Information Panel
Under 21 CFR 101.2(a), the information panel is the label panel immediately to the right of the principal display panel (PDP) as displayed to the consumer — or, if that panel is too small, the next panel to the right.
On a typical rectangular carton or bottle:
Principal Display Panel (PDP): the front face — the panel most likely to be displayed at retail
Information Panel: the panel immediately to the right of the PDP
If the package is cylindrical or has an irregular shape where "immediately to the right" cannot be determined, the information panel is the label area most likely to be seen by the consumer under customary conditions of purchase after the PDP.
What Must Appear on the Information Panel
Under 21 CFR 101.2(b), the following required information must appear on the information panel or the PDP, unless already featured on the PDP:
Name and place of business of the manufacturer, packer, or distributor (21 CFR 101.5)
Net quantity of contents (21 CFR 101.7) — if not on the PDP
Ingredient list (21 CFR 101.4)
Nutrition Facts panel (21 CFR 101.9) or Supplement Facts panel (21 CFR 101.36)
Allergen declarations required under FALCPA and the FASTER Act
Note: The net quantity of contents must appear on the PDP, not just the information panel. It is the only mandatory element that must be on the PDP specifically.
Grouping Requirement
Under 21 CFR 101.2(e), all required information that appears on the information panel must be grouped together — it cannot be scattered across the panel with unrelated graphics or promotional copy between required elements.
This grouping requirement is frequently violated when brands place the Nutrition Facts panel on the back panel, the ingredient list on a side flap, and the name-and-address on the bottom — effectively splitting required information across multiple locations.
Intervening Material Prohibition
Required label information on the information panel must not be interrupted or obscured by:
Decorative graphic elements
Promotional statements
Vignettes or images
Other non-required text
The information panel is meant to function as a clean, accessible block of consumer-relevant required information. Placing marketing copy between the ingredient list and Nutrition Facts panel violates this requirement.
Type Size and Legibility
Under 21 CFR 101.2(c), all required information on the information panel must appear:
Prominently and conspicuously — visible under customary conditions of purchase and use
In type size no smaller than 1/16 inch in height (based on the lowercase letter "o")
With sufficient contrast between text and background to be easily read
These minimum type size requirements interact with package size — on small packages, meeting both the grouping requirement and the minimum type size can require careful label design.
Information Panel for Dietary Supplements
For dietary supplements, the same information panel rules apply. The Supplement Facts panel, ingredient list (Other Ingredients), allergen declarations, and name-and-address must appear grouped on the information panel or PDP. Many supplement products use a wrap-around label where the Supplement Facts panel occupies most of the back or side panel — this is acceptable as long as all required elements are grouped and meet type size requirements.
How Truli Helps with Information Panel Compliance
Label layout audit: Truli verifies that all mandatory labeling elements appear on the information panel or PDP and are grouped together as required
Intervening material detection: Truli flags instances where promotional copy or graphics appear between required label elements
Type size verification: Truli checks that Nutrition Facts, ingredient lists, and allergen statements meet minimum type size requirements
Related Regulations
21 CFR Part 101 — FDA food labeling overview
21 CFR 101.3 — Statement of Identity — What must appear on the PDP
21 CFR 101.4 — Ingredient List — Ingredient declaration requirements
21 CFR 101.9 — Nutrition Facts Panel — Nutrition labeling requirements
Frequently Asked Questions
Can required labeling appear on the bottom of a package?
Generally no. The information panel is defined as the panel immediately to the right of the PDP — not the bottom. Required information on the bottom of a package is typically not considered part of the information panel and may not satisfy placement requirements, unless the bottom is the panel most likely to be seen after the PDP.
My package has a large front panel and small side panels — where does the information panel go?
The information panel is always the panel immediately to the right of the PDP as displayed to the consumer at retail. If that side panel is too small to accommodate all required information, the next panel to the right is used. If there is no right-adjacent panel of adequate size, required information may appear on any panel visible at retail, provided grouping requirements are met.
Can the ingredient list and Nutrition Facts panel be on different panels?
No — under the grouping requirement of 21 CFR 101.2(e), required information must appear together on the information panel, not split across multiple panels.
A note from Truli: Truli is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
Last updated: April 2026. Reflects 21 CFR 101.2 as of April 2026. Book a demo to see how Truli monitors food label compliance.
