21 CFR 101.7 establishes the requirements for the net quantity of contents declaration on packaged food labels. Unlike other mandatory elements that may appear on the information panel, the net quantity of contents must appear on the principal display panel (PDP) — it is the only required labeling element that is legally confined to the PDP.
Where the Declaration Must Appear
Under 21 CFR 101.7(a), the net quantity of contents must appear on the principal display panel. It must be placed in the bottom 30% of the PDP and must appear as a distinct item, separated by at least a space equal to the height of the lettering used.
The declaration may not appear only on the information panel, the back panel, or the bottom of the package — the PDP placement is mandatory.
Expression of Net Quantity
Under 21 CFR 101.7(b), the net quantity must be expressed in terms of:
For weight (solid or semi-solid foods):
U.S. customary: avoirdupois pounds and ounces (e.g., "1 lb 4 oz" or "20 oz")
Metric: grams (g) or kilograms (kg)
Both must appear on the label
For volume (liquid foods):
U.S. customary: fluid ounces, quarts, pints, or gallons
Metric: milliliters (mL) or liters (L)
Both must appear on the label
For count (items):
Numerical count is acceptable when the product is sold by count (e.g., "12 bars")
Count declarations may also need a weight or volume declaration depending on the product type
Dual Declaration: U.S. Customary and Metric
Under 21 CFR 101.7(b), both U.S. customary and metric quantities must appear on the label. The declarations may be placed on the same line or on separate lines. Common formats:
NET WT 12 OZ (340 g)— weight, customary first, metric in parenthesesNET WT 340 g (12 oz)— metric first is also acceptable16 fl oz (473 mL)— fluid volume format
The word "net" must precede weight and volume declarations. For count declarations, "net" is not required.
Type Size Requirements
Under 21 CFR 101.7(i), the minimum type size for the net quantity declaration is based on the area of the principal display panel:
PDP Area | Minimum Type Height |
|---|---|
5 sq in or less | 1/16 inch |
5–25 sq in | 1/8 inch |
25–100 sq in | 3/16 inch |
100–400 sq in | 1/4 inch |
Over 400 sq in | 1/2 inch |
Type height is measured by the lowercase letter "o" in the declaration. For packages with an area between categories, the larger minimum applies.
Calculating the PDP Area
The area of the PDP is calculated differently depending on package shape:
Rectangular carton: height × width of the front panel
Cylindrical container: 40% of the total surface area (height × circumference × 0.4)
Irregular shapes: the area of the largest face or the area most likely to be displayed at retail
The calculated PDP area determines the required minimum type size for both the net quantity declaration and other required label elements.
Fractions and Rounding
Under 21 CFR 101.7(j):
Quantities 1 lb or more but less than 4 lbs: express in pounds and ounces or in decimal fractions of a pound (e.g., "1 lb 6 oz" or "1.375 lbs")
Quantities 4 lbs or more: express in pounds with fractions in decimal (e.g., "5.5 lbs") or in pounds and ounces
Metric quantities: express as a whole number of grams below 1 kg; above 1 kg, express in kilograms with up to 3 decimal places
What Is Not Included in "Net Quantity"
The net quantity of contents is the quantity of the food itself — it excludes packing material, containers, or wrapping. For food in liquid medium (e.g., canned vegetables in brine, fruit in syrup), FDA requires declaration of the quantity of the entire contents — liquid and solid — not just the drained weight, unless a separate drained weight declaration is made.
Dietary Supplement Count Declarations
For dietary supplements sold in unit form (tablets, capsules, softgels, packets), the net quantity of contents is typically expressed as a count (e.g., "90 capsules," "30 softgels," "60 packets"). Some supplement brands also include weight (e.g., "90 capsules | Net Wt 135 g") — this is not required but is not prohibited.
Under 21 CFR 101.36 (Supplement Facts panel), serving size is expressed separately from the net quantity declaration on the PDP. The net quantity is the total content of the package, not the per-serving amount.
How Truli Helps with Net Quantity Compliance
PDP placement verification: Truli confirms the net quantity declaration appears on the PDP in the bottom 30% of the panel
Dual declaration check: Truli flags labels that show only metric or only U.S. customary units without both declarations
Type size audit: Truli calculates the PDP area from label dimensions and verifies the net quantity declaration meets the applicable minimum type size
Format verification: Truli checks that weight declarations use the "NET WT" prefix and are expressed in the correct format for the quantity
Related Regulations
21 CFR Part 101 — FDA food labeling overview
21 CFR 101.2 — Information Panel — Placement rules for other mandatory label elements
21 CFR 101.3 — Statement of Identity — The other PDP-specific required element
Frequently Asked Questions
My product is sold by count — do I need to include weight as well?
For dietary supplements, count alone (e.g., "60 capsules") is typically sufficient. For conventional foods sold by count, it depends on the product category — some foods sold by count (e.g., granola bars in a multipack) also require weight declarations. Review 21 CFR 101.7 and applicable product standards for your specific category.
Does the net quantity need to appear on every display panel?
No — it must appear on the PDP only. However, if the package has multiple identical display panels (e.g., a rectangular box with two front panels), the declaration should appear on both.
Can the metric declaration be smaller than the U.S. customary declaration?
Yes — the U.S. customary declaration may be in larger type, but both declarations must meet the minimum type size requirement based on PDP area. The metric declaration cannot fall below the minimum.
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 101.7 as of April 2026. Book a demo to see how Truli monitors food label compliance.
