Nutrition Labeling Resource
For Mushroom Growers and Marketers
April 2020
Prepared by:
Melissa Grzybowski, MS, RD
Food Consulting Company
www.foodlabels.com
Prepared by: Melissa Grzybowski, MS, RD page 2 of 17
Food Consulting Company, www.foodlabels.com
April 2020
Nutrition Labeling Resource
For Mushroom Growers and Marketers
This nutrition labeling resource was developed to provide mushroom growers and
marketers an overview of nutrition labeling regulations for Nutrition Facts labels and
nutrition marketing claims. This version reflects updates to the Nutrition Facts label as
required by FDA in 2016. Labels must be 100% compliant with the new regulations no
later than January 1, 2020 (January 1, 2021 for manufacturers with less than $10 million
in annual food sales). This revision replaces the previous nutrition labeling resource
information of 2011 and provides a few updates since the 2016 version. Compliance
with these regulations is your responsibility.
In This Resource
Nutrition Labeling Resource For Mushroom Growers and Marketers …..…...…... 3
FDA Updates to the Nutrition Facts Label...…………………………………………. 3
FDA Nutrition Values for Mushrooms ………………………………….…………..… 4
Other Nutrition Values for Mushrooms……………………………….. ….…………. 5
Nutrient database values ……………………………………………………......... 5
Lab-analyzed values …………………………………………………..………..…. 5
Nutrients for Nutrition Facts Labeling ……………………………………….……….. 5
Determining the % Daily Values …………………………………………………….... 6
The Nutrition Facts Graphic …………………………………………………………… 7
Nutrient Content and Health Benefit Claims ………………………………………… 9
Nutrient content claims ……………………………………………………………. 9
Health claims …………………………………………………………..…...…….... 9
Structure / function claims ………………………………………………………… 9
Determining Compliance ………………………………………………………….…... 10
Consequences of Non-Compliance ………………………………………………….. 10
Nutrition Labeling Checklist for Mushroom Growers ……………………………..... 11
Web Links Included in this Resource ……………………………………….…...….. 12
Appendix A: USDA Values for Select Mushrooms ………….……………………... 13
Appendix B: Sample Nutrition Facts for Select Mushrooms….…….………….….. 14
Prepared by: Melissa Grzybowski, MS, RD page 3 of 17
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April 2020
Nutrition Labeling Resource
For Mushroom Growers and Marketers
Under current FDA rules, nutrition labeling on product packaging for fresh fruits and
vegetables – including mushrooms – is voluntary unless a grower or marketer makes
nutrition or health benefit claims on the label or in product advertising. Still, even in the
absence of claims, many mushroom growers opt to voluntarily include a Nutrition Facts
label on the product package to showcase to consumers that mushrooms are low in
calories and sodium, free of fat and cholesterol, and a source of important vitamins and
nutrients. Consumers consider taste, nutrition, cost, convenience and sustainability
when making food purchasing decisions. Nutrition labeling is a way for growers and
marketers to address consumers’ concerns at the point of sale and to encourage them
to purchase nutritious products, such as raw mushrooms.
FDA Updates to the Nutrition Facts Label
The 2016 nutrition label regulations have widespread impact across every product that
bears a Nutrition Facts label.
An overview of the changes:
• Revised format highlights Calories and Servings
• Focus on serving sizes that better reflect what people most commonly consume
• New requirement to include Added Sugars with Percent Daily Value (%DV)
• Nutrition Facts Per Package and/or Per Serving for certain package sizes
• Updated Daily Values (DVs) for several nutrients like fat, carbohydrate, sodium,
potassium and dietary fiber
• Actual gram amount for calcium, iron, vitamin D and potassium in addition to %DV
• Vitamins A and C are no longer required but can be included as voluntary nutrients
• Calories from Fat is no longer allowed on the Nutrition Facts label
• Revised footnote better explains the %DV for consumers
These changes will impact how the nutrition information appears on mushroom labels.
For example, the %DV for fiber and potassium have increased; therefore mushrooms'
contribution to the DV will decrease.
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April 2020
FDA Nutrition Values for Mushrooms
As part of the voluntary labeling program for fresh fruits and vegetables* FDA has
gathered data from many sources, applied statistical analysis, issued a proposed and
final rule, accepted industry comments, and published the following dataset for fruit and
vegetable nutrition in the Code of Federal Regulations (CFR), Title 21, Part 101,
Appendix C. The highlighted data below is FDA’s published nutrition values for white
button mushrooms:
To create FDA-compliant labels, mushroom growers need to keep the following
requirements in mind when developing Nutrition Facts labels for their products:
• White button mushrooms– required to use FDA nutrition values (per 21 CFR
101.45(4b)) See sample Nutrition Facts label graphic on page 7 and Appendix B.
• Generic mushrooms (without mention of a specific variety, species or cultivar) -
should also use FDA nutrition values.
• Mushrooms that are identified on the front of the package as being distinct from
generic mushrooms (for example, “Shiitake Mushrooms”) may still use FDA
nutrition data with regard to serving size and nutrition values,
OR may use values other than those from FDA for nutrition labeling (see page
5); however, in the case of using other values, all labeling requirements specified
in 21 CFR 101.9 must be followed and the serving size must be based on the
85g “reference amount” (per 21 CFR 101.12 for all other vegetables without
sauce). See sample Nutrition Facts label graphic on page 8 and Appendix B.
* The voluntary labeling program for fresh fruits and vegetables is codified into regulation at 21 CFR 101.42.
Guidelines for voluntary labeling under this program are published at 21 CFR 101.45.
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Where to Get Other Nutrition Values for Mushrooms When Needed
For products identified as something other than white button mushrooms or generic
mushrooms, growers may use nutrient database values, lab-analyzed nutrition values or
a combination of the two instead of using FDA's values.
Nutrient database values - USDA has published database values for several varieties
of mushrooms as shown on the chart in Appendix A. It is acceptable to use these
values when developing Nutrition Facts labels for mushrooms that are identified as
being distinct from generic mushrooms (for example, “Shiitake Mushrooms”). To
prepare the data for the Nutrition Facts label, the food labeler needs to determine the
Serving Size representing the household measure (pieces for whole mushrooms, OR
cups for sliced, chopped or pieces) closest to the 85g reference amount established by
FDA. Please note that the values from the USDA database are “per 100 grams.”
Lab-analyzed values – Another option for determining the nutritional composition of
specialty mushrooms is via laboratory analysis. To prepare the data for the Nutrition
Facts label, the food labeler needs to determine the Serving Size representing the
household measure (pieces for whole mushrooms, OR fractional portion of a cup for
sliced, chopped or pieces) closest to the 85g reference amount established by FDA.
Please note that, as with nutrient database values, lab-analyzed values are typically
reported “per 100 grams.”
Nutrients for Nutrition Facts Labeling
Some nutrients are mandatory within the Nutrition Facts label; others are voluntary.
Additionally, the nutrient order and nomenclature used are very important. Below is a
listing of the nutrients allowed within the Nutrition Facts label. Mandatory nutrients are
shown in bold, and the listing is in the order specified by FDA. Nutrients have been
revised to reflect 2016 FDA regulations
Calories
Soluble Fiber
Vitamin C
Choline
Calories from Saturated Fat
Insoluble Fiber
Vitamin E
Phosphorus
Total Fat
Total Sugars
Vitamin K
Iodine
Saturated Fat
Added Sugars
Thiamin
Magnesium
Trans Fat
Sugar Alcohol
Riboflavin
Zinc
Polyunsaturated Fat
Protein
Niacin
Selenium
Monounsaturated Fat
Vitamin D
Vitamin B6
Copper
Cholesterol
Calcium
Folate
Manganese
Sodium
Iron
Vitamin B12
Chromium
Total Carbohydrate
Potassium
Biotin
Molybdenum
Dietary Fiber
Vitamin A
Pantothenic Acid
Chloride
Notes:
The following voluntary nutrients are present in insignificant amounts in all mushrooms: polyunsaturated fat,
monounsaturated fat, soluble fiber, insoluble fiber, sugar alcohol, vitamin K, biotin, iodine, chromium, molybdenum,
and chloride. Because they are insignificant for mushrooms, these nutrients were omitted from the Daily Values
section on page 6 and the example on page 8.
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April 2020
Determining the % Daily Values
FDA has established Daily Values (DV) based on a 2,000 calorie diet. Once the serving
size and quantitative nutrient values are determined, then the food labeler must
determine the % Daily Values that will be reported on the Nutrition Facts label. This is
achieved by dividing the quantitative value by the Daily Value. The FDA-established
Daily Values are as follows:
Total Fat, 78g
Iron, 18mg
Vitamin B12, 2.4mcg
Saturated Fat, 20g
Potassium, 4700mg
Pantothenic Acid, 5mg
Cholesterol, 300mg
Vitamin A, 900mcg RAE
Choline, 550mg
Sodium, 2300mg
Vitamin C, 90mg
Phosphorus, 1250mg
Total Carbohydrate, 275g
Vitamin E, 15mg
Magnesium, 420mg
Dietary Fiber, 28g
Thiamin, 1.2mg
Zinc, 11mg
Added Sugars, 50g
Riboflavin, 1.3mg
Selenium, 55mcg
Protein, 50g
Niacin, 16mg NE
Copper, 0.9mg
Vitamin D, 20mcg
Vitamin B6, 1.7mg
Manganese, 2.3mg
Calcium, 1300mg
Folate, 400mcg DFE
2016 FDA regulations include a revised and much shorter %DV footnote: “The % Daily
Value tells you how much a nutrient in a serving of food contributes to a daily diet. 2000
calories a day is used for general nutrition advice.” The changes in the DVs will also
impact nutrition labeling for mushrooms and potentially the ability to make claims. For
example, potassium DV increased from 3500mg to 4700mg. Previously, a serving of
mushrooms was required to have 350mg potassium to be labeled “good source of
potassium”. Now, a serving must contain 470mg of potassium for the same claim.
Notes:
There is no established Daily Value for Trans Fat or Total Sugars.
% Daily Value for Protein is optional and is typically omitted on fruits and vegetables. If used, the labeler must use a
protein digestibility corrected amino acid score (PDCAAS) to correct the protein value before determining the % Daily
Value. The Mushroom Council has available Protein Digestibility lab results for Agaricus Bisporus (White) Mushrooms
with a PDCAAS = 0.46.
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April 2020
The Nutrition Facts Graphic
The Nutrition Facts label is not the platform for your label designer to exercise creative
talent! FDA has very specific rules for color, font, size, kerning, leading, weight of lines
and outlines for Nutrition Facts labels. It is recommended that you use print-ready
Nutrition Facts art provided by a professional food labeler, or consult Code of Federal
Regulations at 21 CFR 101.9 and FDA Graphic Examples for graphic specifications.
Notes:
FDA has special rules for Nutrition Facts labeling for fresh fruits, vegetables and fish – including mushrooms. When
FDA nutrition values are used, the servings per container line may be omitted if desired. Raw fruits, vegetables and
seafood are also exempt from dual column labeling.
A tabular Nutrition Facts label layout may be used if there is insufficient vertical space (about 3”) for the horizontal
layout. For smaller packages, additional options include the use of approved abbreviated nutrient names and the “not
a significant source” statement. For more examples of graphic layouts, see FDA Graphic Examples
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April 2020
The sample Nutrition Facts label shown below has been expanded to show several voluntary
nutrients: Thiamin, Riboflavin, Niacin, Vitamin B6, Folate, Pantothenic Acid, Phosphorus, Zinc,
Selenium, and Copper.
Nutrition Facts Label for Sliced
Light-Exposed White Button Mushrooms
using USDA Nutrition Values
Note:
This example uses 1 cup (85g) as the Serving Size (compared to 84g shown on the sample Nutrition Facts labels on
page 7 for generic mushrooms). The serving size for Nutrition Facts labels for mushrooms identified as being distinct
from generic mushrooms must be based on an 85g “reference amount.” (See 3
rd
bullet at bottom of page 4.) FDA
guidance available here gives more information for determining the serving size for non-generic mushrooms.
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April 2020
Nutrient Content and Health Benefit Claims
Nutrient content and health benefit claims made on a product label or in advertising
must follow all regulations established by FDA, which are published in the Code of
Federal Regulations, Title 21, Parts 101.13, 101.14, 101.54-69, and 101.70-83.
Products with label claims face greater scrutiny than those without claims, but growers
who have a good understanding of the regulations (or seek consultation from food
labeling experts who do) do not need to shy away from communicating nutritional
benefits of mushrooms on package labels.
The following is a sampling of nutrient content claims and their definitions:
• Free means a product’s reference amount and labeled serving contains an insignificant amount
of total fat, saturated fat, cholesterol, sodium, sugars, or calories. If the product is naturally free
of the nutrient, then the labeler must indicate that the food inherently qualifies for the claim
(e.g., mushrooms, a fat-free food)
>> Synonyms: zero, no, without, trivial source of, negligible source of
• Good source means the reference amount of a product contains 10 to 19% of the Daily Value of
a particular nutrient
>> Synonyms: contains, provides
• Excellent source means the reference amount of a product contains 20% or more of the Daily
Value of a particular nutrient
>> Synonyms: high in, rich in
• More means the reference amount of a product contains at least 10% or more of the Daily Value
of a nutrient than the reference product
>> Synonyms for altered products: fortified, enriched, added, plus
• Healthy for raw fruits and vegetables means that the food contains 3g or less fat, 1g or less
saturated fat, 480mg or less sodium and 60mg or less cholesterol per reference amount or
labeled serving (whichever is larger). Note, FDA is considering a change to how “healthy” is
defined. This definition may be revised in the future.
>> Synonyms: non specified
Health claims are pre-authorized by FDA, must use tightly-controlled wording and must
characterize the ability of the nutrient or functional component to reduce the risk of
disease or a health-related condition. At this time, there are 17 approved health claims
and mushrooms do not qualify for any of them. (Mushrooms do not qualify for the
health claim related to calcium, vitamin D, and osteoporosis because they do not
contain the qualifying amount of calcium.)
Structure / function claims describe the role of a nutrient or functional component in
affecting or maintaining normal body structure or function. This type of claim is not pre-
approved by FDA, but the grower must have substantiation on file to show that the claim
is truthful and not misleading, and be prepared to back up the claim, if challenged.
(Structure / function claims can be a useful way for a grower or marketer to highlight the
health benefits of vitamin D in light-exposed mushrooms.)
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April 2020
Determining Compliance
FDA regulations establish the allowable variance for random testing of the product vs.
what is printed on the label. If FDA decides to verify the accuracy of a nutrition label for
a product, the agency will conduct nutrition analysis on a composite sample of 12
packages collected from 12 separate shipping cases. The results of this analysis will be
compared to the product label.
In addition to the nutrition values displayed on the label, FDA also monitors compliance
with established nutrient content claims, other health benefit claims, nutrition facts
formatting, ingredient labeling, product naming, net weight declaration, overall label
layout and text size/positioning.
In all cases, every aspect of the label must be truthful and not misleading; otherwise the
product is said to be misbranded.
Consequences of Non-Compliance
If FDA determines the label values are not compliant, or if the product is misbranded or
misleading in another way (such as invalid claims, incorrect serving size or incorrect
formatting), the agency will most likely issue a written warning that asks for a response
within 15 days. These warning letters are a matter of public record, FDA publishes
them on the Internet, and they can carry the potential for significant negative press.
FDA may also levy fines, seize product or force a recall.
Remember, compliance with the nutrition labeling regulations is the responsibility of the
firm who carries the signature line on the product.
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April 2020
Nutrition Labeling Checklist for Mushroom Growers
All answers should be YES. If you check NO or are unsure about any of the items on
the checklist, you may wish to consult with a food label expert to ensure that your labels
are 100% FDA compliant.
No.
Item
YES
NO
1
If my package contains white button mushrooms or is labeled simply as
“mushrooms” does the Nutrition Facts label (NFL) contain the required FDA
values shown in 21 CFR 101.9 Appendix C reflected in the new 2016 NFL
format?
2
If the nutrition values on my label are not consistent with FDA values for
mushrooms, does my label include the name of the variety, species or
cultivar within the product identity on the front of the package?
3
If the product identity on my package is something other than “mushrooms”
or “white button mushrooms” and if I have used values other than those
published by FDA for mushrooms, do I have data to support the values I
am using?
4
Have vitamin declarations been adjusted to account for storage or other
degradation issues so that the values shown on the package reflect what’s
in the package for the entire duration of the shelf life?
5
Does my Nutrition Facts label meet FDA’s graphic requirements shown in
21 CFR 101.9 and FDA Graphic Examples?
6
Does my Nutrition Facts label include the Daily Values footnote (revised
version as noted on page 6)?
7
Does the Serving Size shown on my Nutrition Facts label include a
household measure showing the number of mushrooms (for whole
mushrooms) OR fractional portion of a cup (for sliced, chopped or pieces)
that comply with FDA regulations?
8
Does the Serving Size shown on my Nutrition Facts label follow FDA’s
Reference Amounts Customarily Consumed and represent the whole
number of pieces or fractional portion of a cup nearest 85 grams?
9
If the Servings Per Container line is used, does it work together with the
Serving Size line and make sense in the context of the declared net weight
shown on the front of the package?
10
Have the values shown in the Nutrition Facts label been rounded per FDA
rules?
11
If my label contains any nutrition or health benefit claims, am I certain that
they meet regulatory requirements?
12
If claims are made about a nutrient that is ordinarily voluntary (for example,
Riboflavin), does my Nutrition Facts label include the required listing for that
nutrient?
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April 2020
Web Links Included in This Resource
Nutrition Facts for Raw Fruits and Vegetables, 21 CFR 101 Appendix C
https://www.ecfr.gov/graphics/pdfs/er17au06.008.pdf
Nutrition labeling of raw fruit, vegetables, and fish, 21 CFR 101.42
http://www.ecfr.gov/cgi-bin/text-idx?SID=cc31fffb98fe4c00655fc0138a670653&mc=true&node=se21.2.101_142&rgn=div8
Guidelines for the voluntary nutrition labeling of raw fruits, vegetables, and fish, 21 CFR
101.45
http://www.ecfr.gov/cgi-bin/text-idx?SID=cc31fffb98fe4c00655fc0138a670653&mc=true&node=se21.2.101_145&rgn=div8
Nutrition labeling of food, 21 CFR 101.9
http://www.ecfr.gov/cgi-bin/text-idx?SID=cc31fffb98fe4c00655fc0138a670653&mc=true&node=se21.2.101_19&rgn=div8
Reference amounts customarily consumed per eating occasion, 21 CFR 101.12
http://www.ecfr.gov/cgi-bin/text-idx?SID=cc31fffb98fe4c00655fc0138a670653&mc=true&node=se21.2.101_112&rgn=div8
USDA’s FoodData Central
http://www.ars.usda.gov/Services/docs.htm?docid=8964
Graphic Enhancements Used by the FDA – Resources for Industry
http://www.fda.gov/downloads/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/LabelingNutrition/UCM513883
.pdf
Guidance for Industry: Guidelines for Determining Metric Equivalents of Household
Measures
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-guidelines-determining-metric-
equivalents-household-measures
Nutrient content claims – general principles, 21 CFR 101.13
http://www.ecfr.gov/cgi-bin/text-idx?SID=cc31fffb98fe4c00655fc0138a670653&mc=true&node=se21.2.101_113&rgn=div8
Health claims: general requirements, 21 CFR 101.14
http://www.ecfr.gov/cgi-bin/text-idx?SID=cc31fffb98fe4c00655fc0138a670653&mc=true&node=se21.2.101_114&rgn=div8
Specific Requirements for Nutrient Content Claims, 21 CFR 101.54-69
http://www.ecfr.gov/cgi-bin/text-idx?SID=cc31fffb98fe4c00655fc0138a670653&mc=true&node=sp21.2.101.d&rgn=div6
Specific Requirements for Health Claims, 21 CFR 101.70-83
http://www.ecfr.gov/cgi-bin/text-idx?SID=cc31fffb98fe4c00655fc0138a670653&mc=true&node=sp21.2.101.e&rgn=div6
Appendix A: USDA Values for Select Mushrooms per 100g
Values of “0” represent insignificant amounts for that nutrient. Values of “–“ represent no data available for that nutrient.
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Appendix B: Sample Nutrition Facts for Select Mushrooms
Sample Nutrition Facts
for Crimini Mushrooms
Sliced, 8 oz Package
Sample Nutrition Facts
for Portabella Mushrooms
Whole, 12 oz Package
Example claims:
Mushrooms – a low calorie food
Mushrooms – a fat free food
Mushrooms – a saturated fat free food
Mushrooms – a cholesterol free food
Mushrooms – a very low sodium food
Mushrooms – a sugar free food
High in Riboflavin, Niacin, Pantothenic Acid, Selenium and
Copper
Example claims:
Mushrooms – a low calorie food
Mushrooms – a fat free food
Mushrooms – a saturated fat free food
Mushrooms – a cholesterol free food
Mushrooms – a very low sodium food
Mushrooms – a sugar free food
High in Niacin, Pantothenic Acid, Selenium and
Copper
Sample Nutrition Facts
Sample Nutrition Facts
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for Shiitake Mushrooms
Whole, 1 Pound Package
for Oyster Mushrooms
Whole, 1 Pound Package
Example claims:
Mushrooms – a low calorie food
Mushrooms – a fat free food
Mushrooms – a saturated fat free food
Mushrooms – a cholesterol free food
Mushrooms – a very low sodium food
Mushrooms – a sugar free food
High in Riboflavin, Niacin, Pantothenic Acid and
Copper
Good source of Thiamin
Example claims:
Mushrooms – a low calorie food
Mushrooms – a fat free food
Mushrooms – a saturated fat free food
Mushrooms – a cholesterol free food
Mushrooms – a very low sodium food
Mushrooms – a sugar free food
High in Niacin and Pantothenic Acid
Good source of Riboflavin, Vitamin B6, and Copper
Prepared by: Melissa Grzybowski, MS, RD page 16 of 17
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April 2020
Sample Nutrition Facts for White Button
Mushrooms using FDA Nutrition Values,
1 Pound Package
Sample Nutrition Facts for Sliced
Light-Exposed White Button Mushrooms,
12 oz Package
Example claims:
Mushrooms – a low calorie food
Mushrooms – a fat free food
Mushrooms – a saturated fat free food
Mushrooms – a cholesterol free food
Mushrooms – a very low sodium food
Mushrooms – a sugar free food
Example claims:
Mushrooms – a low calorie food
Mushrooms – a fat free food
Mushrooms – a saturated fat free food
Mushrooms – a cholesterol free food
Mushrooms – a very low sodium food
Mushrooms – a sugar free food
High in Vitamin D, Riboflavin, Niacin, Pantothenic Acid, and
Copper
Good source of Selenium
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April 2020
Sample Nutrition Facts for Diced
Maitake Mushrooms, 1 Pound Package
Example claims:
Mushrooms – a low calorie food
Mushrooms – a fat free food
Mushrooms – a saturated fat free food
Mushrooms – a cholesterol free food
Mushrooms – a very low sodium food
Mushrooms – a sugar free food
High in Vitamin D, Niacin and Copper
Good source of Thiamin and Riboflavin