Q: Do I need a nutrient analysis and nutrition facts panel if I label my product gluten-free, sugar-free, vegetarian, etc.?

A: No. These claims do not trigger the nutrition facts panel requirement for cottage food exempt products. To qualify as gluten-free, any unavoidable presence of gluten in the food must be less than 20 ppm. Sugar-free claims contain less than 5 calories per reference amount customarily consumed and per labeled serving. Learn more about FDA's gluten-free food labeling rule and food labeling. If you add a health claim (i.e. reduces heart disease) on your label, you need nutrients analyzed and add a nutrition facts panel on the label.