Mandatory vs Voluntary Nutrients on Nutrition Facts Panels: 2020 FDA Format Rules

The 2016 FDA label update dropped vitamins A and C from the required nutrient list and added vitamin D and potassium in their place. If your Nutrition Facts panel was built before that transition, the mandatory section may be missing a required nutrient, declaring an optional one as if it were required, or both. This covers the current mandatory list, the optional list, and the single most important rule about when optional nutrients stop being optional.

The Mandatory Nutrient List Under 21 CFR 101.9

These nutrients must appear on every standard Nutrition Facts panel in the following order, per 21 CFR 101.9:

• Calories
• Total Fat — with Saturated Fat and Trans Fat as mandatory sub-items
• Cholesterol
• Sodium
• Total Carbohydrate — with Dietary Fiber and Total Sugars as mandatory sub-items, and Added Sugars indented under Total Sugars
• Protein
• Vitamin D (%DV)
• Calcium (%DV)
• Iron (%DV)
• Potassium (%DV)

Vitamin D and potassium were added to the mandatory list because of documented public health concern—both are nutrients that Americans are deficient in at population scale. Vitamins A and C came off the mandatory list for the inverse reason: deficiency in the general population is no longer considered a public health concern in the U.S.

The Voluntary Nutrient List

Any nutrient not on the mandatory list is voluntary—you may declare it, but are not required to. Commonly declared voluntary nutrients include:

• Vitamins A and C (formerly mandatory, now optional since the 2016 update)
• Thiamin (B1), Riboflavin (B2), Niacin (B3), Folate, Vitamins B6 and B12
• Magnesium, Zinc, Selenium, Manganese, Chromium, Molybdenum, Chloride, Phosphorus
• Any other vitamin or mineral with an established FDA Daily Value

If your product has a real nutritional story around a voluntary nutrient—your granola is a meaningful source of magnesium, your beverage is fortified with B12—you can declare it. Some manufacturers continue to declare Vitamins A and C because consumers expect to see them. That is a label strategy decision, not a compliance requirement. The rule is you may include them; you are not penalized for omitting them.

When Voluntary Becomes Mandatory

This is where small food manufacturers get caught. Under 21 CFR 101.9(c): if you make a nutrient content claim about a voluntary nutrient anywhere on the label, that nutrient must appear on the Nutrition Facts panel.

Examples of claims that trigger mandatory declaration:

• Front panel says “Good source of Vitamin C” → Vitamin C is now required on the Nutrition Facts panel
• Package says “High in Magnesium” → Magnesium must appear with a %DV value
• Label includes “Contains Zinc” → Zinc must be declared on the panel
• Marketing copy on a side panel says “Rich in B vitamins” → individual B vitamins referenced in the claim must be declared

Once declared—whether mandatory or voluntarily included—a nutrient is subject to the same compliance requirements: the declared %DV must be accurate, and the value is subject to FDA’s 80/120 compliance tolerance. If your label says “15% DV Vitamin C” and analytical testing shows your product delivers less than 12% DV (80% of 15%), the label is misbranded. Adding a voluntary declaration is not free—it creates a compliance obligation.

Protein — The %DV Exception

Protein is mandatory as a declared gram amount on every label. The %DV for protein is a different story: it is required only if the product makes a protein content claim (such as “good source of protein” or “high protein”), or if the product is intended for children under 4 years of age, or if the product is an infant formula.

When protein %DV is required, it must be calculated using a protein digestibility-corrected amino acid score (PDCAAS) methodology—not by dividing gram protein by the 50g Daily Value. A product with 10g protein per serving and a PDCAAS of 0.8 would declare a protein %DV of 16% (10g × 0.8 / 50g), not 20%. This distinction matters most for plant-protein products, where PDCAAS values below 1.0 are common. The complete protein quality assessment method is covered in FDA’s Nutrition Facts label guidance.

Common Compliance Problems in Practice

Pre-2016 labels still in circulation: labels that show “Vitamin A ___% Vitamin C ___% Calcium ___% Iron ___%” in the bottom row are using the pre-2016 format. If those labels are still on product going to market, they are technically out of compliance. The compliance deadlines were January 1, 2020 for manufacturers with $10 million or more in annual food sales, and January 1, 2021 for smaller manufacturers.

Marketing claims added after label creation: when a reformulated product or new packaging runs add a “good source of zinc” callout, the Nutrition Facts panel needs to be updated in the same label revision to declare zinc. The claim and the panel must be synchronized. A label review checklist that includes “check all nutrient claims against NFP declarations” catches this before the print run.

E-commerce listings and digital marketing: nutrient content claims made on Amazon product pages or brand social channels are technically subject to the same FDA rules as label claims, though enforcement focuses primarily on physical labels. The underlying rule applies to “labeling,” which the FDA defines broadly to include written material that accompanies a food product.

Use the nutrition facts calculator to verify that your panel declarations match current mandatory requirements before sending artwork to your label vendor. Label corrections after a print run cost more than getting the declaration right the first time.

Reference Table: Mandatory vs Voluntary

For the mechanics of calculating %DV for each mandatory nutrient, see percent daily values on nutrition labels: reference amounts, rounding, and exemptions. For the complete panel format requirements—type sizes, margins, dual-column triggers—see creating FDA-compliant Nutrition Facts labels.