LABELS: Do Say, Don’t Say

KEG pickle-making workshop

The labeling requirements for San Diego Cottage Foods are listed in the registration application–but there’s more that is required by state and federal law.  Also, some words should not be used to describe your product.  Save yourself time and trouble down the road by using these tips to get your label right from the start…

According to San Diego County Department of Environmental Health, Food and Housing Division, you

DO SAY the following on the primary label of your packaged Cottage Food product:

1. The words “Made in a Home Kitchen” in 12-point type

2. The name commonly used for the food product

3. The name of your Cottage Food Operation which produced the food (The name you have registered with the Dept. of Environmental Health)

4. The common or usual names of the ingredients listed in descending order by weight.  Sub-ingredients must be included and can be listed following the name of the ingredient.  For instance: enriched flour (wheat flour, niacin, reduced iron, thiamine, mononitrate, riboflavin and folic acid).

5. Your registration or permit number.  (Note: The terms Permit or Registration reflect whether or not you want or have an A or B permit. Wording is very precise re. the county department approving your application. For precise wording see San Diego
Environmental Health Department’s SAMPLE LABEL information.)

AND According to CA state law through AB1616, the Homemade Food Act, it also must have

6.  The address of your Cottage Food Operation

7.  The net weight or volume or count of the food product stated in both English (pounds/ounces) and metric (grams) units.  (It should include the weight of liquid in the package if the liquid is normally also consumed.)

PLUS the Federal Government also requires that you

8.  Declare in plain language if the food contains any of the 8 following major food allergens (or ingredients derived from them)


You can note the allergens in a separate statement immediately following or next to the ingredient list OR within the ingredient list.  Cottage Foods Sandie recommends listing any allergens separately beneath the ingredients so as to avoid causing a bad allergic reaction in your customer due to them overlooking the allergen in the ingredient list!

Don’t Say

The Federal Food and Drug Administration has specific conditions for the use of these terms. (For instance, sodium free means the product has less than 5 mg of sodium per serving.  Use of these terms may require you to get, and display, a nutritional analysis which is currently NOT needed for cottage food products in California.)

2.  Anything that describes a relationship between a food component and a disease or health-related condition is considered a health claim.  Phrases like “sodium and hypertension,” or “calcium and osteoporosis” are defined and regulated under 21 CFR 101.14 and 101.70 et. seq.


And Remember:

  • Labels must be in English (but can have a translation on the label or package)
  • If you will be providing unpackaged/labeled products to a food facility, the facility must identify the product as homemade to their customers.
  •  If you label your product as “Organic” it must be certified by an accredited third party certifying organization.  That organization’s name must appear on the label
  • Glossy labels often reproduce and look better than matte.  Experiment to get the right “look” for your product and packaging.
  • Any labels, wrappers, inks, adhesives, paper, or packaging materials that come into contact with your cottage food product by touching the product or penetrating the packaging must be food-grade (safe for food contact) and not contaminate the food.
  • Labels don’t have to be boring! Use color, designs, and graphics to make them visually appealing. Just make sure to have the right information.

For an example of a label acceptable to the San Diego Environmental Health Department, please see this LABEL link

Have questions, comments, or experiences you’d like to share? We’d love to hear them!


Skip to comment form

    • Elaine on January 22, 2013 at 12:47 pm
    • Reply

    Thank you for your website it is extremely helpful.
    I am selling something like homemade peanut brittle by the pound. So, I am not sure not how to do the weight as each package will be different. If you could please let me know what to do I would greatly appreciate it.
    Thanks –

    1. Kind words appreciated! For the permit, just take a package with the appropriately weight on the label so they can see a sample. When selling, why not leave the oz. blank (_____ oz/____g) and fill it in for the customer when you’ve weighed it out. Cottage Food Sandie thinks that should keep everyone happy 🙂

        • Elaine on January 23, 2013 at 7:58 am
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        Thank you very much for your quick response and helpful answer. I am actually blown away that I can type in a question and get a direct response. I am curious if you work for the county or if you are helping all of us fledgling food makers for fun? In either case, I sincerely thank you. I will keep you informed of my progress.

        1. Cottage Food Sandie is a home-based cottage food operator, too! I had to find the information for myself so why not share it and promote all of us entrepreneurs? Yes, it is fun. Don’t forget to join our Facebook Page where we anticipate some lively discussions and helpful hints in the future.

    • Joy Danzig on January 26, 2013 at 4:38 pm
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    Thanks for your reply on TFL, and this is just great! I’ll keep checking in with you.

  1. I was wondering if there could be two labels? One with the company name and logo and product name and weight, and a seperate label for ingredients and permit #. Thank you

    1. Good question! Yes, you can have a Primary Display Panel (PDP) and a secondary Information Panel (IP). The PDP must have the food’s common name or a “fanciful” name with a descriptive phrase at least 1/2 the type size of the product name. The product name must be in bold letters. Other information required on the PDP includes the net quantity (in English lbs/oz and in metric kg/g) and the words “Made in a Home Kitchen” in 12 point type. Other information can be included on the IP such as Ingredients, Allergens, and the Cottage Food Operation name, permit #, address (street, city and state). For Class B permits, the name of the county health agency issuing the permit must be on either label. For more details see the state publications on labeling Cottage Foods here UPDATE: See comment below. SD Environmental Health requires all the information be on the primary label. If you have Nutritional Analyses done, that can be on a secondary label.

      1. Wow, so informative, thank you so much for getting back to me so quick. Im getting all my things together now so I can apply early next wee. THANK YOU, LOVE THIS SITE!!

    • Linda on March 11, 2013 at 1:24 pm
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    I’m having trouble fitting all the information on my label and when I split it up the way you suggest it still doesn’t fit. How about if on one label I put my cottage kitchen name and address and permit # and on the other label I have product name, made in home kitchen, ingredients, allergens, and weight?



    1. UPDATE: We are now allowed to list ingredients on a secondary label rather than squeeze everything onto one label. The secondary label can be on the side, bottom, or other area of the package. YAY!!

    • Luna on March 11, 2013 at 3:26 pm
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    Thank you very much for all the information it’s so helpful, all this is driving me crazy because I can’t find the information explained so well and easy like you do, it’s kind of dificult and confusing if we dont have experience in running a business or doing labels, I’m trying to get my licence to sell my custom cakes, I assume that I need a label for each flavor, in the label can I put the ingredients for the cake part, than for the filling and then for the frosting, or do all the ingredients have to go together? I think my labels are gonna be huge because can you imagine listing all the igredients of all my ingredients, like for the fondant and the gel color to paint my fondant and then for the CMC powder to make the fondant into gumpaste 🙁 this driving me crazy and I haven’t even started yet, really thank you very very much

    1. I agree!! I will see if we can get the state to clarify it (though I’m not sure that the county has to go along with it as they have jurisdiction and enforcement powers.)
      At least there’s no specific instruction on HOW it has to be written on the label so it can theoretically run around the edges, or your label can be on the box and stretch over the side (or bottom or back). And the font can be small for the ingredients (as long as an ‘average’ person can read it). I would just make sure to BOLD any allergens. The ingredients have to be listed in order by weight but if you are using a commercial ingredient you list its ingredients (in parentheses) after its name. I would think it would be ok to separate the ingredients into the categories (Cake, Filling, Frosting) and list ingredients of each in order by weight. Then you could just put that “block” into the space on a label template.
      Be prepared, though, to submit a sample label for your permit application that has everything in one long list, just in case. (Luckily, CMC powder is simply Cellulose Gum.)

    • Jenny on March 13, 2013 at 2:34 pm
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    Hello, I just earned my ServSafe Food Safety Manager certification, but haven’t ever worked in a commercial kitchen. I’m getting ready to apply for a Class B. Can you give some pointers on what to use to sanitize my baking equipment (pans, etc.)? I know there are options, but when I search online nothing comes up under “commercial sanitizing solutions”, etc. Specifically, what chemicals do I buy, and how do I dilute? Where do I buy these? Can I keep this on-hand in a pre-mixed spray bottle? Thank you…

    1. An inexpensive, easy way to sanitize your cooking equipment and utensils is to submerge the clean (washed, rinsed) items into a sanitizing solution made by mixing 1 tablespoon unscented household-strength chlorine bleach in 1 gallon of warm (not hot) water. Hot water causes bleach to dissipate, weakening the solution. Remove items, shake off the excess and air dry. Chlorine evaporates and leaves no residue. The solution should be made fresh each day but can be used over and over again to sanitize your clean utensils.

    • The Cake Lab on April 8, 2013 at 9:16 pm
    • Reply

    First… Without this websit I would have never been able to make the tremendous progress that I have. In just a few short weeks I have secured a business name, filed a business license and get all of my tax number etc. I am onto the next step of actually applying for the cottage food permit with the label and had a few questions. First, do I need to only provide the county one sample label?

    Second, can I just any item that I bake to use as the sample label?

    Third, on the label it wants my permit number. Do I just enter a fake number because I don’t know my permit number yet? Or is that referring to my sellers permit number?

    Thanks again! Hopefully I will be at a Farmers Market soon 🙂

    Would live a post about jumping through those hoops.

    1. Thank you for the kind words! Glad we can help. Sounds like you are rapidly making progress. As for your label(s), how many products do you plan to have? Best to have a sample label for each one since every product will need to be labeled anyway. Where you would include your permit number you can just put XXX in it’s place. Beware though that SD County CFO permit numbers are about 18 or 20 digits long! Are you applying for an A or B permit? Watch for our next post on selling at Farmer’s Markets! Also, check out our Facebook page re. a new farmer’s market…

        • The Cake Lab on April 15, 2013 at 6:48 pm
        • Reply

        I make cakes and plan on doing cupcakes at the farmers market once I am permitted. I went to the Environmental Office and yes I have to have a label submitted for every flavor combination and a lot of the frosting recipes aren’t approved that u butter( even if its non perishable). So a little frustrating/ disappointing but trying to modify my menu.

        1. That is frustrating. Thanks for sharing the info for others!

    • Kevin on May 22, 2013 at 5:08 pm
    • Reply

    When labeling food colorant, do you have to specify the color # or simply the general color? Thank you!

    1. Whatever the food colorant ingredients are is what should be listed. For instance, Ingredients: Sugar, Water, …, Food coloring (Water, Propylene Glycol, FD&C Red 40, 0.1% Propylparaben)

    • Kevin on May 23, 2013 at 8:12 pm
    • Reply

    Thank you for the quick response! 🙂

  2. I have a question can I say gluten free on or about my product? I was also wondering can anyone share how they may have “dressed up” the label with such limited space I dont see how you can

    1. As stated, you cannot use the words “Free, low, reduced, fewer, high, less, more, lean, extra lean, good source, or light” on your label. To make the label more attractive, use color, different fonts, different size font (only Made in a Home Kitchen must be in 12 pt. type), and use graphics which can have the type over top.

    2. Environmental Health NO LONGER recommends emailing them a copy of your label for pre-approval. They started getting overwhelmed and no longer do pre-approvals.

    • Lydia on May 28, 2013 at 8:04 am
    • Reply

    Thank you so much for this website, it’s a wealth of information! I have a couple of questions about labels…

    – Is there guidance on where the secondary label must be situated (can it be on the bottom of a jar, for example?)

    – and what if you eventually expand your range of goods or flavors…would you have to go back to the Dept. of Environmental Health?

    Thank you!

    1. There is no stipulation as far as we know about where a secondary label can be. Just be sure all the specified information is on the primary label. Yes, if you expand or change your products, you must get approval from the Health Department. Thank you for the kind and encouraging words re. the site!

  3. When i was in getting my license Ryan said if I was to add a new flavor I would just need to fax or email the info for the new flavor

    • Lydia on June 3, 2013 at 10:52 am
    • Reply

    Thanks for your help, Cottagefoods – I went in last Thursday for my license and all was perfect!

    Bridget, did they tell you that you’d have to pay an additional $142 for adding new flavors? That’s what I was told…that I should “save any new ones up” until it made sense to pay an additional $142. It’s making me rethink add-ons!

    1. No Ryan did not say anything other than above I think I would have remembered cuz I would have a heart attack to pay for another permit lol I really hope this is not true

      1. SD Environmetal Health is now saying they will apply their hourly rate ($142/hr) to review additional labels that were not part of the initial CFO application. You can fax or email the new labels and the charge can be billed to you.

        1. $142 an hour???????

          1. Seriously

    • Monika on June 9, 2013 at 10:17 am
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    Thank you so much for this website! I have been afraid to even look into doing this because it seems so daunting, but your website has so much info I think I can actually tackle it!

    So, I am also planning on doing custom cakes. They will vary so much in size and ingredients, that I am very confused about my labels. The cakes can be a simple 6″ round to 5 tiers. How do I do a sample label for all of my cake flavors, filling flavors and decorations when there could be a million combinations?

    1. It would be easiest to start with the basics — a basic cake recipe which can be simply modified for a few flavors. Then a frosting that will be approved. Know that most butter cream or cream cheese frostings will not be approved. (Our next post will be on the frosting dilemma.) Start with a simple, basic menu that you can get approved before applying for your license. Do separate ingredients lists for the cake and frosting. Be sure your menu and sample labels are approved in advance so you don’t pay for the permit without being able to sell anything! Best advice: start simple.

    • Linda on July 23, 2013 at 10:04 am
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    I have a couple of label questions. First off we plan on selling different sizes of our cookies, what should we put for the weight on our sample label? Can we just use one label with one weight or do we need a different sample label with each weight even though the ingredients are the same? And we plan on using a round label for individual packaging and a rectangular label for multi-packaging since both will have the same ingredients do we need a sample of each or will one be sufficient? Thank-you so much for all of your help!!

    1. You can label your product by count instead of weight if that helps with your cookies (i.e. 1 doz., or 16 ea.) It wouldn’t hurt to provide a sample label of each, but as long as the information is the same on both (other than the amount) I cannot imagine it would really matter!

    • Dave on August 12, 2013 at 6:08 pm
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    Any recommendations on printing durable labels for jars? I have ink jet but don’t know that I can print anything durable enough. Success may bring commercial labels, but not until I get up and running.

    Great site and a fabulous resource!

    1. Thanks for the kudos! We like for their prices, variety, and support. Check out their Learning Center, Customer Creations, or call for questions/service. Email us if you need links to any of the aforementioned.

        • Roger on August 13, 2013 at 1:31 pm
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        Do you have a recommended vendor for ready-made labels, rather than blank labels I can print? I’d rather just buy them; better quality anyway.

        And if I’m reading this correctly I need to have labels for each possible flavor of product I plan to produce to avoid being charged again, is that correct? I have 6 flavors I’d like to do eventually, but only 3 that will be going up at first. Is it better to send them all at the same time? I already know them, which I guess is helpful.

        I think I want the ingredients to be on the same label with the logo, etc. That doesn’t sound like a problem provided they meet the size and content requirements. I hope. 🙂

        1. We don’t have a recommended label maker–had to do our own graphics, etc! 🙂 But you can check out for people who will produce a label for you inexpensively. Contact each “gig” with the information you will need included. All the information (except ingredients and allergens) must be on the primary label. As of 2014, ingredients and allergens can be on a separate, secondary label posted on the side, back or separate front area. There are ways to incorporate your logo. Of course, you can have an additional sticky with just your logo!
          And yes, you are better off getting all the products and labels you will need (including flavor variations) approved at the start–otherwise it is $142 minimum to evaluate/approve additional labels through San Diego Environmental Health.

    • Puja on October 15, 2013 at 3:35 pm
    • Reply

    I have question about the labels. Can I print labels at home on my regular printer?

    Do I need to have nay special type of ink or requirements for labels?

    1. No requirements other than the wording. Yes, you can print from home!

    • Puja on October 16, 2013 at 1:08 pm
    • Reply

    Thanks for you reply,
    More and more questions
    If I use a commercial ingredient say Chocolate chips. The sub ingredients may be slightly different from brand to brand. I may find a better version tomorrow on a very good price but I find there are 1 or 2 minor ingredients which are different in two brands. Do I need to approve a different label in that case?

    1. Technically, yes, you would need to change the label and get the new one approved. Best to have your recipes and ingredients/suppliers all worked out beforehand, though sometimes that’s very difficult.

    • Puja on October 17, 2013 at 11:12 am
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    Hi All,

    Some information to share with all of you.The new amendments made by SDEH dept. describes 9 different things to be incorporated in the labels in which only Ingredients can be put on secondary or information labels. And they are not allowing to submit your labels by email/.fax any more.

    Any more updates?

    • Puja on October 23, 2013 at 7:21 pm
    • Reply

    Hi Again,

    Thanks for sharing the information with us. It has been extremely helpful.

    Please suggest where to get packaging material like plastic boxes/bags

    1. Check out our Facebook page for discussions on suppliers that people use and like.!/pages/San-Diego-Cottage-Foods/478571155526458

    • Roger on October 24, 2013 at 8:46 am
    • Reply

    Couple more questions:

    The branding for my business is still being put together, but I didn’t want something like finishing a logo design to prevent submitting the paperwork to get the CPO license going. Can I submit ‘plain vanilla labels’ and later modify their look to accommodate the new branding/logo as long as I don”t materially change what is approved (such as ingredients, font sizing, address info, etc.)? Or does the brand, logo, stylization, etc. need to be 100% finished when submitted?

    Also, does it need to be on an actual label, or can it be a proof on an 8.5×11 sheet of paper that will eventually be put on to a label?

    1. So sorry…just saw this reply never got posted! SD Health Dept. would like the labels as final as possible, but recognizes some graphic/branding changes may occur. As long as the approved wording, font, etc. does not change significantly, the addition of graphics, colors, styling, etc. is fine. They actually PREFER it be on paper rather than the actual label in case changes need to be suggested.

    • Allison on December 30, 2013 at 11:52 am
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    I am planning to to baked items; cakes, cookies, bars, cupcakes for events. Since my products are not packaged, do I need to provide labels for all the products when I apply for my permit?

    1. Yes, every product you want to sell must be pre-approved with a label detailing its ingredients and other required information. You will only be permitted to sell the items listed on your permit so be sure to include all the labels for any variations in flavors/ingredients. You can add flavors/variations later, but the labels will have to be approved and the cost is $142/hr. Best to include them all at the start, if possible.

    • Stephanie on March 22, 2014 at 7:49 am
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    How do you list the weight for cakes and cupcakes? Depending on the size of the cake or cupcake, some require more icing and fillings then others. Are there any examples to view specifically for cakes and cupcakes?

    Thank you so much for this wonderful website, it is so helpful!!!

    1. Thank you for your kind, encouraging words! 🙂 Labels must contain the net weight or volume or COUNT of the food product, so you could say Count: 1 dozen (i.e., for cupcakes) or Count: 1 (or 1 each) each for a cake.

        • Audrey on May 25, 2016 at 1:40 pm
        • Reply

        Hi Cottage Foods!

        Thank you so much for all your help, you are awesome! I just wanted to clarify on this question. I will be selling fudge. I make the fudge in a large sheet and then cut it into squares to sell individually. The individual pieces will all be slightly different weights since I am cutting them by hand. Instead of weighing each piece of fudge (which would take FOREVER), are you saying that I can label it “Count: 1 each”? Is this correct? That would save so much time if so.

        1. Not sure if the Health Department will let you do that for fudge. It is typically used for cakes, cookies, cupcakes, etc. Most likely, you will need to go by weight and the best way to do that would be to cut the fudge into the size and number of pieces you’d typically sell, weigh each, and take an average. The weight does not have to be to many decimals, it could just be 0.2 oz or 0.5 oz. If there’s a little MORE than labeled, that’s ok. It’s when you are selling less than advertised on the label that it is a problem.

    • Michelle on March 24, 2014 at 12:15 pm
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    I have a question pertaining to the word “organic”. I know using the word to describe the food item as a whole requires further certification, but can I label organic ingredients as such in the ingredient list?

    Thanks in advance!

    1. Yes, your ingredients can be described as organic (i.e, organic almonds)

        • Michelle on March 24, 2014 at 1:54 pm
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        thanks for the quick response! You have a very informative site here. It’s answered a lot of questions for me… thanks again! 🙂

        1. Thank YOU! 🙂

    • Danielle on June 1, 2014 at 11:26 am
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    I’m making cake pops so as you can imagine the product is very small. 2 questions:
    1. does each pops have to have it’s own label, or can I bundle them in dozens and label the package?

    2. If I do sell them individually, can I attach a “tag” to a ribbon and use that as my label in order to incorporate all my ingredients?

    thank you for this website, it less intimidating and encouraging

    1. You can definitely package them together and label the package (making sure the count is noted on the label). And we don’t see why you couldn’t attach your label to ribbon for individual sales. Again, note on the label the count (1 in this case). Remember you can fold the label in half with your ingredients on one side and your other information on the primary side.
      Thank you for the encouraging words!
      PS. you can now have your ingredients listed on a separate label

    • Asa on June 8, 2014 at 4:30 pm
    • Reply

    Hi Cottage Foods Sandie,
    Question: I am planning to start my cake CFO this summer and had a question regarding the sample labels needed for getting the permit. Do you have to have every type of flavor/food label available? Does this restrict me from adding cake flavors and types later in the year. How does that work if one wants to add holiday flavors/items or does not have all of their recipes worked out at this time?

    Sorry for all the questions. Any help is appreciated! Thanks, -Asa

    ps I love this website and facebook. It has been EXTREMELY helpful!

    1. In San Diego, it is important to carefully consider how many products and labels you will need. The basic cost of a permit is $142 (a B permit is $284 because it’s an extra $142 to come out for the inspection) and includes review of your labels. If you have so many labels that it takes more than an hour to review your application and labels, it could cost an additional $142. Every item that has different ingredients will need its own label, so yes…every flavor would need a separate label to be reviewed. If you want to add items (including new flavors) during the year, it will cost another $142/hr to review them. There is no provision for partial hour billing. 🙁 SO, plan carefully and add new flavors and items at renewal, if possible. Thank you for your kind comments!

    • April on August 11, 2014 at 11:19 am
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    Question- Is a food handler course and exam the same thing as a food processor course? I can’t seem to find a food processor course anywhere, only food handler courses keep popping up.

    1. No, a food handler and a food processor course are not the same. For a CFO license, you would need a food handler card from an approved vendor (online or in class).

      1. On their web page, the county calls the online options for CFO food handler training “state food processor courses.” Don’t be confused by their terminology. They are referring to the state’s approved online classes for CFOs versus the county in-person classes. The link for the online clases is here Of those, we’ve found eFoodHandlers Inc. to be the least expensive AND you cannot lose money. Take the test until you pass, then pay.

  4. How many labels are normally reviewed, or about how many would take up the entire hour. I am worried between all my cake flavors, frosting flavors, and labels for cake pops that it might be too many, but then again I have no clue so, maybe I have way less than average.

    Another big concern: the label reqs say to have it in 12pt font. Which is fine but with all the ingredients for cakes it seems it will make a rather large label. Is there no way to make it smaller, for instance, if am selling my cake pops or a small boxed cupcake individually at a farmers market and someone just buys one, do I just have to hand them a huge label card. Ideally I’d like to have a smaller label “tag” to tie on, but these are just so big with 12 pt 🙁

    1. Re. the number of labels, remember you can now have TWO, a Primary and a Secondary. Only the ingredients (and allergens) can be listed on the Secondary label. The words “Made in a Home Kitchen” have to be in 12 pt. font, but everything else can be a different size. (See the response below re. type/font size.) If you don’t change your Primary Label much (other than the name of the type of cake pop for instance) they will be fast to review. The bigger question is the cake and frosting. I would suggest a Primary label with the name of the cake pop. The secondary label would include cake ingredients, then frosting ingredients – with every pop a different cake/frosting. Once all the cake flavors and frostings are approved, it shouldn’t be an issue to use a different frosting, as long as the right ingredients are listed for that flavor. (However, the Health department may disagree, wanting every possible combination listed).
      Fewer than 10 labels can usually be done while you wait. More than 10 often means the Health Department will review them over the next 5 days. They encourage you to submit sample labels can be submitted on regular paper. Labels are submitted with the entire application. There is no magic number of labels as some are more complicated than others.
      In the beginning, you might start with 5 cake and 5 frosting flavors (unless the ingredients don’t vary much) and use them in multiple combinations. That keeps your operation from getting too complicated but allows enough flexibility to see what flavor combinations are most popular.

    2. Another thought is perhaps you can make a small tag that goes on the stick with your primary info on one side and ingredients on the other. I’m thinking of something like a long, narrow label that you fold in half around the stick. People can tear it off and still keep the tag with your contact info. 🙂

      1. While the words “Made in a home kitchen” must be 12 point, the rest of the type has a size requirement as well. The rest of the text needs to be at least 1/16” as measured from the lower case “o”. This is to ensure that the text is not too small.

        Some fonts are inherently smaller then others, so 12 point in one font could be significantly smaller then 12 point in another. So, whatever font you use, make sure the lower case “o” measures at least 1/16″ or your labels will be rejected.

    • Beth on September 13, 2015 at 1:21 pm
    • Reply

    Your site is fabulous! I’m looking forward to being approved for my CFO, and your website has been a huge help in the process! THANK YOU! 🙂

    My question is regarding labeling: when you use a food color gel, must that be listed on the ingredient list. If yes, must we list the sub-ingredients of each color used?

    Thank you so much for your help!

    1. Thank you for your kind and encouraging words. I hope when we say that Yes, the sub ingredients of the food color gel(s) used in each product must be listed, it does not discourage you 🙂

    • Klancy on November 8, 2015 at 5:53 pm
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    I know you clarified about being able to use the word “organic” in the ingredients list if an ingredient is organic, so along that same line of thought, can we list something in the ingredient list as gluten free (i.e. gluten free flour blend (rice flour, almond flour, etc etc))? And just not use the words “gluten free” on our actual product (i.e. gluten free cupcakes)? And do you know if we can market our food as gluten-free, say with a sign next to our food, without actually putting it on the label? I’m trying to figure out how to let customers know that can’t eat gluten that my product is for them. Thanks so much for the help and all the information on the site!

    1. If the name of the ingredient has gluten free as part of its name, then it can be listed in the ingredient panel. But, if the ingredient is called flour blend, for example, and the words “gluten free” are listed somewhere on its packaging, then you would not be able to list it as gluten free on the ingredient panel of your CFO product.

      That said, having advertising at a point of sale booth is not a regulated portion of the Cottage Food Law. The law only focuses on the package itself. It should not be a problem if a vendor indicates that they sell gluten free food on a sign on their booth, as long as it doesn’t directly relate to a specific product.

        • Klancy on November 20, 2015 at 7:51 am
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        Thank you so much for the information!

    • Sharon on March 15, 2016 at 2:12 pm
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    Hello again!
    I was wondering if Swiss meringue buttercream frosting was allowed? I understand it has eggs in it so it might automatically be a no, but considering you put it in a double boiler till it reaches 160, I was wondering whether that counts as “a product baked”?

    Thank you so much!

    1. Good question! Here’s the answer and explanation from the health department:

      Even though the product has been cooked, it is still egg, which is a potentially hazardous food, both cooked and uncooked. It doesn’t fit into the “product baked” category, as it doesn’t meet the normal definition of a baked good. I know eggs are used as ingredients in a baked product, but the consistency of the product changes when baked, reducing the water activity of the product. Low water activity is one of the defining characteristics of a non-potentially hazardous food. CDPH is specific on the restrictions for frostings “Buttercream frosting, buttercream icing, buttercream fondant, and gum paste that do not contain eggs, cream, or cream cheese.” So, no, it would not be approved.

    • wendy on May 26, 2016 at 11:52 am
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    Hi, I am selling an Organic product and wondered if your website mentions it must be certified by an accredited third party certifying organization. Where would you recommend I go for that?

    Thank you!

    1. You are correct that labeling something as Organic requires an approved 3rd party to analyze your product and officially stamp it. For more information about organic labeling and possible work-arounds, click here . Under directories, there is a page for Organic Certifiying Agents here (

    • Megan Brockbank on August 26, 2016 at 2:11 pm
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    This website has been so helpful. I wish I had found it sooner. I am started a jam selling business and had a couple of questions.
    1- I was directed to take the NRFSP course to become a food manager. I already passed the test. Was that the right one? I’m starting to panic thinking all the studying was a waste!
    2- For my labels, I’m getting conflicting reviews-what can go on the secondary label besides ingredients? Can the permit number go on there? What else? Do the items have to be in a certain order? It seems the sample label is a bit outdated, especially with the secondary label option.
    3-I’m a bit overwhelmed about the inspection. Is there a list somewhere about the procedure? Do they check your refrigerator/freezer temps, etc.?

    Thanks so much for your help. It’s so appreciated.

    1. #1 You did not need to take the NRFSP course. You may still need to take one of the courses approved for CFOs from this LIST prior to, or within 3 months of, getting your permit. See our post HERE for our recommendation.
      2. The secondary label cannot have any information other than ingredients. It should note any ingredient considered an allergen either by bolding it in the ingredient list, or listing them separately as Allergens: xxx. See the San Diego County Health Dept’s label instructions HERE or search this website with the word LABELS for additional or updated information.
      3. See our post on surviving your inspection and what to expect HERE They will check your water temps but not refrigerators/freezers. Check out the “self certification” list on A permit applications for a good starting list of do’s and don’ts.

    • Ingrid Vitale on February 6, 2017 at 2:38 pm
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    Hello!! and thank you so much for this wonderful site!
    I have a few questions for the labels

    1. when selling cake pops – I use cake box mix- should I list all the ingredients of the box or should I just put cake box mix?
    2. I sell oreos and rice krispie treats covered in chocolate that are prepackaged. How should I label those?

    Sorry for the long questions.

    Thank you in advance 🙂

    1. You will need to list all of the ingredients of the box under “Cake:” or “Cake pop: and you also will then need to list under “Frosting” or similar name all of the ingredients used in the frosting or fondant (whether homemade or purchased off the shelf). Also, under “Decorations” you will need to list ingredients of any decorations used.
      Will you be covering the oreos and rice krispie treats with chocolate yourself? You would list the cookie or krispie ingredients, then list “Chocolate coating” and the ingredients of that. We would advise caution if you are just buying specific brand cookies/krispies and repackaging as your own product. “Repackaged in a Home Kitchen” was designed for things like bulk teas, coffee, etc. We recommend modifying the cookies/krispies in some way to make them your own ‘new’ product for sale under your own label.

        • Ingrid Vitale on February 7, 2017 at 10:56 am
        • Reply

        Thank you so much for your response!
        Yes, I’ll be covering both in chocolate and add decorations to it with fondant and or chocolate.
        This is great info! Thanks again for for your time 🙂

    • Mel on May 22, 2017 at 11:06 am
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    Hi I’m planning on selling cookies. On the label, is it still ok to put the count for example 1 dozen, 12 pcs instead of net weight/volume? Also when submitting the labels for approval, does it have to be the actual label that you will be putting on the packaging or just a draft with all the required info? For example, do I just print it on a white paper and then submit it? Can I also change the label (just appearance/graphics not content, name of item or ingredients)Thank you for all your help.

  5. You can include the count of your cookies but also must have the weight in oz and g per Federal requirements. Always better to be a bit under than over weight if you are not weighing the packages individually before selling. When submitting the labels, you should submit a sample that corresponds to the actual size of label you will be using. It can be printed on plain white paper but should reflect the actual label size you will use. You can change the graphics but the information needs to remain the same once approved. Also remember sizes–Made in a Home Kitchen must be in 12 point font and other wording must be in a font size where an ‘o’ is at least 1/16 of an inch high.

    • Catherine on September 27, 2017 at 1:53 pm
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    Hi. I am planning to bake vegan goods. Can the word vegan be on the label AND OR the ingredients list?

    How would I describe an item like sugar in the ingredients list? Most sugars are not vegan because they are processed with bone char, unless it’s organic. Would I list it as “organic sugar” or “vegan sugar”

    What about “vegan butter” followed by the ingredients in the ” vegan butter”

    1. Vegan is not considered a nutritional claim and is therefore allowed on your label without requiring a Nutritional Panel. However, unless your sugar (or butter) is sold as organic or vegan, it should just be listed in ingredients as Sugar (or butter, followed by its component ingredients).

    • sharon on October 10, 2017 at 8:59 am
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    hi there. I am new to all of this and really need some guidance.

    I am wanting to get my cottage food B permit and want to make sure i have made all the steps correctly.

    I saw the application, check list, and label info so i will be completing these steps and sending them in.

    But i am signed up to work an event in December and need all this completed before then.
    Is this possible? should i cancel the event?

    I have tried called cottage food (san diego) and it just goes to the voicemail and I feel a bit defeated at this point. Especially since I am doing all this solo.

    any help would be amazing.
    thank you

    • Rachel on July 25, 2018 at 11:14 am
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    I am applying for my CFO and I just have to start off by saying your site has been SO helpful! Thank you!

    My question is that I know meringue powder is not approved because of the egg whites and I know every county is different. But do some counties approve the use of meringue powder?

    I ask because I make sugar cookies with royal icing (which has the meringue powder) and there are so many people that do this as well and are licensed with their food label, but I am not sure how they got it approved because they all use meringue powder. I am wondering if there is a way around that or an alternative to getting it approved that I am missing? Thank you in advance!!

    • Camille Bernardo on March 13, 2019 at 12:32 pm
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    how would you go about labeling a gluten free cupcake?

    • Rachel De La Cruz on December 2, 2019 at 9:12 am
    • Reply

    I need to have my lable made for my baking goods so if I can help

  6. I need to have my lable made for my baking goods so if I can help e

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