How to label grab-and-go food: label template and date rules

A grab-and-go case sells without anyone asking a question. A guest picks up a wrap, reads the label and decides. If the label says "Chicken wrap" and nothing else, they can't see the sesame in the dressing, and you can't show an inspector what's in it either.

This post covers what the FDA Food Code says goes on a label, how date marking works, a label template, and the routine that keeps the case honest.

General information, not legal advice. Labeling is governed by federal law and by your state and local rules, which can add requirements. Check with your health department or state agriculture department before you print.

When food needs a label

The Food Code, the model code most state and local health departments adopt in some form, says food "PACKAGED in a FOOD ESTABLISHMENT, shall be labeled as specified in LAW" (§3-602.11(A)). Wrapping a sandwich in film and putting it in a case to sell is packaging it.

Food you portion or bag for a guest at the counter is different. Bulk, unpackaged food, "such as bakery products", and food "portioned to CONSUMER specification" need no label if, among other conditions, "There are no state or local LAWS requiring labeling" and no health or nutrient claim is made (§3-602.11(D)). A croissant you pick from the case with tongs is usually unpackaged; a croissant you pre-bag and leave on a shelf is packaged.

Unpackaged food still has an allergen duty: the permit holder "shall notify CONSUMERS by written notification of the presence of MAJOR FOOD ALLERGENS as an ingredient in unPACKAGED FOOD items" (§3-602.12(C)). A card or sign by the pastry case is a common way to do it.

What goes on the label

Under §3-602.11(B), label information shall include:

Food Code item	What it means on a café label	Example
(1) "The common name of the FOOD"	What it is, plainly	Chicken Caesar wrap
(2) A list of ingredients "in descending order of predominance by weight", including subingredients	Biggest ingredient first, including what's inside each component	Flour tortilla (wheat flour, water, oil, salt), chicken, romaine, Caesar dressing (oil, egg yolk, Parmesan cheese, anchovy, lemon juice, garlic)
(3) "An accurate declaration of the net quantity of contents"	The weight	Net wt. 9 oz (255 g)
(4) "The name and place of business of the manufacturer, packer, or distributor"	Your business name and address	Your café's name, street, city, state, ZIP
(5) The food source of each major food allergen, unless it's already in the ingredient's name	The allergens, named	Contains: wheat, egg, milk, fish (anchovy)

The Code also lists nutrition labeling (6) "Except as exempted in the Federal Food, Drug, and Cosmetic Act". Whether your café is exempt is a question for your state agency or a labeling consultant. Don't print nutrition claims ("low fat", "high protein") unless you know the rules for them.

The allergens

The Food Code defines major food allergens as "Milk, EGG, FISH (such as bass, flounder, cod, and including crustacean shellfish such as crab, lobster, or shrimp), tree nuts (such as almonds, pecans, or walnuts), wheat, peanuts, soybeans and sesame" (§1-201.10(B), "Major food allergen").

The trap is the subingredients. A pesto has pine nuts (a tree nut) or walnuts; a "vegan" mayo may contain soy; bread may have sesame seeds on the crust or sesame flour in the dough. Read every component's label, and write it down once, on the master list below, so no one has to guess at 6 a.m. Our allergen matrix template is a good place to keep it.

Dates: the seven-day limit

Most grab-and-go food is ready-to-eat and needs temperature control, so date marking applies. The Food Code says ready-to-eat TCS food prepared and held for "more than 24 hours shall be clearly marked to indicate the date or day by which the FOOD shall be consumed on the PREMISES, sold, or discarded when held at a temperature of 5ºC (41ºF) or less for a maximum of 7 days. The day of preparation shall be counted as Day 1." (§3-501.17(A)).

Two rules that catch people out:

The oldest ingredient sets the date. A combined food "shall retain the date marking of the earliest-prepared or first-prepared ingredient" (§3-501.17(C)). A wrap made today with chicken cooked three days ago has three days used up already.
Seven days is a maximum, not a target. Most cafés sell sandwiches and salads the same day or the next, because quality goes well before day 7. Set your own shorter shelf life for each item and put that date on the label.

Food past its date, or with no date, "shall be discarded" (§3-501.18(A)).

For the guest, many cafés print a plain "Sell by" or "Enjoy by" date. For the kitchen, the date the item was made matters too, so put both on the label.

The label template

Line	What to print
Name	Chicken Caesar wrap
Ingredients	In order by weight, subingredients included
Contains	The major food allergens, named
Net weight	oz and g
Made on	Mon 12/28
Sell by	Tue 12/29
Keep refrigerated	For TCS food
Made by	Your café's name and address

Print it on a label printer or pre-printed stickers with blanks for the dates. Handwritten dates are fine, as long as they're readable and in the same format every day.

The master list

Make one master list, kept in one place, with one row per item. The person packing the case copies from it; nobody writes ingredients from memory.

Item	Net wt.	Contains	Shelf life (days, Day 1 = made)
Chicken Caesar wrap	9 oz	Wheat, egg, milk, fish	2
Hummus and veg box	8 oz	Sesame	2
Overnight oats	10 oz	Milk, tree nuts (almond)	3
Fruit cup	8 oz	None	2

The daily routine

When	What	Who
Packing	Label from the master list; "Made on" is today; "Sell by" is today + shelf life − 1	Prep
Packing	Oldest ingredient checked: if the chicken was cooked Monday, Monday is Day 1	Prep
Stocking the case	Oldest in front; case at 41°F or below	Opener
Midday	Case temperature on the temperature log	Shift lead
Close	Pull everything with today's sell-by date; record it on the waste log	Closer
Weekly	Compare pulled items with sales; pack fewer of what's pulled most	Manager

Check before you print

[ ] Every ingredient on the master list matches the supplier labels you have now
[ ] Subingredients are listed (dressings, sauces, breads, spreads)
[ ] Every major food allergen is named, including sesame
[ ] Net weight checked on a scale, not estimated
[ ] Your business name and address on every label
[ ] Made-on and sell-by dates, with Day 1 counted correctly
[ ] No nutrition or health claims you can't support
[ ] Your state or local rules checked for anything extra
[ ] Allergen card for unpackaged items in the case

When a supplier changes, check the master list the same day. A new brand of bread, dressing or granola can bring a new allergen. Our guide to the prep cook role covers training staff on labeling and date marking.

Where Mays fits

The master list where the team can find it. Keep it as an article in the Knowledge Base, with a table per item. Staff read and search it in the Mays app. See Your knowledge base.
The pull on the closing checklist. Add Pull grab-and-go with today's sell-by date to the closing template, with a Photo answer of the empty shelf. See Creating a checklist template.
The weekly label check. A Weekly checklist template, on the day your deliveries come in, with Master list checked against supplier labels. See Scheduling and assigning checklists.
What gets pulled. Record pulled items in the waste log, so the weekly review uses real numbers. See Waste log.

What Mays doesn't do: it doesn't print labels, and there's no screen to enter or show allergens on items or recipes. Print from your label printer's software, using the master list.

A label a guest can trust

The name, the ingredients in order, the allergens named, the weight, who made it and the date to pull it, copied from one master list every time. Pull on the date, check the list when a supplier changes, and the case can answer every question a guest would ask.

Start your free trial: 30 days, every module, no card needed. Or book a walkthrough and we'll set up your closing pull with you.