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Nutrition labels are inaccurate. This is why. And, here are our estimates.

written by

Aaron Miller

posted on

January 27, 2023

In the food industry, nutrition labels are voluntary. If you’ve bought one of our products, then you know that we choose to NOT include nutrition labels. There are a few reasons why:

  1. We don’t want to spend extra money on testing and label approval and then pass that cost along to you. It costs about $800-1000 per sample.
  2. We don’t want to spend extra time on testing. We’d rather focus on being an amazing and reliable source for the highest quality farm direct, nutrient dense food.
  3. Nutrition labels are notoriously inaccurate.

Let’s dive deeper into that last point.

The FDA allows up to 20% difference between what’s on the nutrition label and what’s accurate. Yes, you read that correctly. The nutrition labels are not required to be accurate. And the rules change based on the type of nutrients.

Class I nutrients are those in fortified or fabricated foods. This happens when milk is fortified with vitamin D, when orange juice is fortified with vitamin C, or when cereal is fortified with fiber. Class I nutrients must be present at 100% or more of the declared value on the label.

For example, if a product states that it has 2.7mcg/serving of vitamin D, then the lab test must show 2.7mcg/serving or more to be in compliance. It could be 10 or 100 or 1000mcg/serving and still be in compliance.

Class II nutrients are naturally occurring nutrients, present in the food because that’s what the food naturally contains. In other words, vitamins, minerals, protein, carbohydrate, dietary fiber, fat, etc that are present in the food without fortification. Class II nutrients must be present at 80% or more of the declared value.

Let’s take Vitamin C as an example. Let’s say that the nutrition label says that there is 6mg/serving of Vitamin C naturally occurring in the food. When the product is tested, as long as there is at least 4.8mg/serving (80% of 6mg), then the label is in compliance.

Lastly, there are the Third Group nutrients, which include calories, sugars, total fat, saturated fat, cholesterol, and sodium. Third Ground nutrients must have a lab analysis that’s 120% or less of the declared value.

For example, let’s say a product claims 6g of total fat per serving. The lab test must show no more than 7.2g of total fat per serving (20% more than 6g). It could have 3 or 5 or 7g and still be in compliance.

So, right from the start, you can see how this is tricky. Nutrition facts are estimates. And now it gets more complicated.

Oftentimes, foods aren’t actually being tested. The ingredients are sent to a bot, and the bot shoots out FDA-compliant nutrition facts.

Companies, especially small businesses like us, may want to avoid the $800-1000 fee for testing one sample. Or, they might want to speed up the process; you can get the results back from the bot instantly.

The way it works is you enter your recipe into a nutrition fact generator. You’d type in 1 cup flour, ½ cup butter, 1lb ground beef, 2 tsp salt, etc. And then, magically, it gives you a nutrition label! It uses its database of ingredients to do this.

Of course this isn’t accurate. It’s obviously an estimate. And, it’s a wild estimate for a company like Miller’s that’s producing natural foods with varying nutritional profiles. 

The nutritional profile of food changes with the soil, the farming practices, the season, and the batch.

Soil matters. There’s a big difference in the nutritional value of a carrot grown in the 1920s when topsoil was deep and healthy and a carrot grown today in depleted soil topped with synthetic fertilizers. 

Farming practices matter. There’s a big nutritional difference between conventional beef that’s fed GMO corn and soy and 100% grass-fed, regeneratively farmed beef. 

The season matters. Spring milk, when the cows first start eating 100% spring grass, is yellower and more nutrient dense than milk from the winter, when the cows are eating 100% dry pasture.

The batch matters. Miller’s products are artisanally made in small batches. Yes, we use machines, but there’s a lot of hand work involved, too. The time of fermentation, the pH, the amount the bone broth cooks down, and so on are all a little variable. There’s a human element that decides when it’s “done”. We do our best to keep things consistent, but each batch has a unique flavor, texture, and nutritional value.

Despite all of the above, I know that counting calories or macros (or other things) is important to some people, especially those trying to heal or improve their health. So, I made a little guide.

The new Real Foods Nutrition Facts Guide is mostly based on estimates, comparing our products to similar store bought products that do have nutrition labels. Some of the data is very accurate. For example, the amount of sodium in the cheese has been calculated.

And, right now, it only contains dairy, eggs, and meat. I will likely add more as customers request it.

📙 Check out the new Real Foods Nutrition Facts Guide here

What do you think about nutrition labels? Do you rely on them? If yes, why? If no, why not?

I’d love to hear from you. Comment below (no account required - start typing for the guest option to appear) or contact us.



  1. Guidance for Industry: Guide for Developing and Using Data Bases for Nutrition Labeling
  2. ReciPal

Health and Nutrition


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