Selling Frozen Pizza Through Other Stores? Trace Every Sub-Ingredient Before You Approve the Label

If your pizzeria sells frozen pizzas through other shops or online, the label needs a full ingredient statement. That means more than "crust, sauce, cheese, mushrooms." Federal law requires the common or usual name of each ingredient. For a component made of several ingredients that has an established common or usual name or a federal standard of identity, FDA's regulation gives two ways to declare it, and both show every ingredient inside it. You can name the component and list its ingredients in parentheses, or you can drop the component name and fold each of its ingredients into the main list by weight. Whether a house name like "pizza crust" or "pizza sauce" meets that condition is something this answer couldn't confirm, so the worked draft below is conditional. The allergen declaration is a separate check that comes after the full trace, not a substitute for it.

The practical rule: before you approve the label, build a ledger from each component's specification or recipe. Record each supplier's ingredient statement word for word as evidence, put the components in order by their weight in the finished pizza, and only then work out the "Contains" line. The ledger is what you check a label against. It isn't finished label text. Stop and get the missing piece if a specification or weight is missing, if a supplier groups ingredients under "2 percent or less," or if you can't confirm a component's name qualifies for the method you're using. Don't guess weights from memory or from the order on a supplier's label.

Why this came up now

On October 1, 2026, Saint Francis Apizza LLC of Cincinnati announced a voluntary recall of its frozen pizzas because soy was not declared on the label. FDA posted the company's announcement on October 3. The notice covers its Pepperoni, Plain Cheese, Supreme, and Mushroom and Onion frozen pizzas. They were sold through shops in Ohio and Kentucky and online at cincyfavorites.com. The notice's title says the label was missing sub-ingredients for soy, naming soybean oil and soy lecithin.

If you bought one of those pizzas, the company's instruction is to discard it or return it to Saint Francis Apizza for a full refund. The notice says no illnesses had been reported.

The notice doesn't describe what the label looked like. It doesn't say which component carried the soy, and it doesn't say whether the soybean oil was highly refined. That last point matters, as explained below. The recall isn't a new labeling law. Its title points to sub-ingredients, which is the part of a label this answer covers.

What the federal rules require

This covers FDA-regulated packaged food. Meat-topped pizzas can fall under USDA instead, as explained in the next section.

• An ingredient statement. A packaged food made from two or more ingredients must list the common or usual name of each one (FD&C Act section 403(i)). FDA's regulation, 21 CFR 101.4(a)(1), requires them "in descending order of predominance by weight." FDA's Food Labeling Guide puts it plainly: the ingredient that weighs the most is listed first.
• A "2 percent or less" exception. Ingredients at 2 percent or less by weight can be grouped at the end of a statement after a phrase like "Contains 2 percent or less of." The descending-order rule doesn't apply inside that group (21 CFR 101.4(a)(2)). So a supplier's list that uses one isn't in weight order all the way through.
• Two ways to declare a component that has its own ingredients. Under 21 CFR 101.4(b)(2), an ingredient that is itself made of two or more ingredients and has an established common or usual name (or meets a standard of identity) can be declared either way. Option one is its name "followed by a parenthetical listing of all ingredients contained therein in descending order of predominance." Option two is to list every one of its ingredients in the main statement, "in descending order of predominance in the finished food," without naming the component. Both depend on that condition. The sources we used don't say which house component names meet it, or what to do when one doesn't.
• Oils by their source. Each fat or oil is declared by its specific name, such as "soybean oil" (21 CFR 101.4(b)(14)). A plain "oil" doesn't meet that.
• The allergen declaration. If the food contains any of the nine major food allergens (milk, eggs, fish, crustacean shellfish, tree nuts, wheat, peanuts, soybeans and sesame), the food source has to be named, either in the ingredient list, as in "lecithin (soy)," or in a "Contains" statement right after or next to it (FD&C Act section 403(w)). If you use a "Contains" statement, FDA's guidance says it must name every major allergen in the food, not just the ones the list doesn't already show.
• Hidden carriers still count. An incidental additive, such as a processing aid, can be left out of the ingredient list under 21 CFR 101.100(a)(3). FDA's guidance says that if it is, or contains, a major food allergen, the allergen still has to be declared.
• Retail-packed food is covered. FDA's allergen guidance says these requirements "extend to foods packaged by a retail or foodservice establishment that are offered for sale." The exception is food wrapped or boxed after a customer orders it. A frozen pizza packed ahead for another store's freezer isn't that.

Soybean oil and soy lecithin are not the same question

The law's definition of "major food allergen" excludes "any highly refined oil" made from one of the nine foods, and any ingredient made from that oil. FDA's guidance describes highly refined oils as refined, bleached, deodorized oils. It also says the source still goes in the ingredient list. So a highly refined soybean oil is still written as "soybean oil." It just doesn't, by itself, put soy in the "Contains" line. If the oil is not highly refined, the soy has to be declared.

Soy lecithin is a different ingredient. It isn't an oil, so the refined-oil exclusion doesn't cover it. FDA's own consumer page uses "lecithin (soy)" as its example of declaring an allergen in the ingredient list. An ingredient can be exempted through FDA's petition or notification process. FDA's petition inventory lists several soy lecithin requests. One, received in 2022, is marked "Pending" on the version FDA last updated in January 2024. Unless your supplier shows you a granted exemption that covers its exact ingredient and use, declare soy.

One more trap: "soybean oil" appearing in the list doesn't count as declaring soy for a soy lecithin elsewhere. The statute says the food source name elsewhere in the list doesn't satisfy the requirement when it's part of the name of an ingredient that isn't a major food allergen, which is what a highly refined oil is. Write "soy lecithin" or "lecithin (soy)," or put soy in the "Contains" line.

Which rules apply to your pizza

• Sold through other shops or online: the federal ingredient statement and allergen rules above apply to the packaged pizza.
• Selling in New York too? New York has its own allergen notice for some grab-and-go food, explained in our guide to New York's grab-and-go allergen label law. This answer doesn't decide whether or how that law applies to any sale. It covers the federal ingredient statement.
• Meat-topped pizzas may be USDA products. FDA's labeling guide points producers of meat, poultry and egg products to USDA. When FSIS dropped its meat-pizza standards in 2003, it described 2 percent cooked or 3 percent raw meat as the level that makes a pizza a meat food product under USDA jurisdiction. If you top it with pepperoni or sausage, this example doesn't apply. Ask USDA's Food Safety and Inspection Service how that product has to be labeled.
• Permits, licensing and food safety are outside this answer. It doesn't cover whether selling to other businesses changes the licenses, registrations or inspections your kitchen needs. Ask your state agriculture or health department before you sell wholesale.

Worked example: a made-up frozen pizza

Sample Street Pizza and every recipe, supplier, specification and weight below are invented for this example. They aren't from a real business or a real supplier. The pizza is a roasted mushroom and pepper pie, assembled on a purchased par-baked crust and frozen without baking, so the example treats each component's weight as it goes on as its weight in the finished pizza. It's sold through two other shops and the pizzeria's website.

The component ledger

Start with one row for every component, the weight that goes on each pizza and the document that tells you what's inside it. The supplier text in this table is recorded word for word as evidence. It isn't approved label text yet.

The pizza weighs 670 g as assembled (300 + 150 + 110 + 70 + 40). The roasted mushrooms lose 385 g in the oven (1,035 g in, 650 g out). Even if all of that loss is water from the mushrooms, 615 g of mushroom is still far more than the 30 g of oil and 5 g of salt. So their order inside the parentheses doesn't depend on whether you count before or after roasting.

What this example can and can't show

Read this before the drafts below. The ledger lets you check three things: whether every ingredient inside every component is accounted for, the order of the components by weight, and which major allergens the pizza contains. It can't settle whether each component name qualifies for FDA's parenthetical method.

• Supported: low-moisture part-skim mozzarella cheese and enriched flour both have federal standards of identity (21 CFR 133.158 and 137.165). That meets the regulation's condition. Standardized foods can have their own rules for optional ingredients inside the parentheses, so the supplier wording for these two is still ledger evidence that needs that check.
• Not verified: "pizza crust," "pizza sauce," "roasted mushrooms" and "crushed tomatoes." We didn't find a source that establishes these as established common or usual names. That's missing support, not a finding that the names are wrong.

So the drafts below are conditional. They assume the unverified names qualify. If they don't, the parenthetical layout shown here can't be used as written, and the sources we used don't spell out the alternative. Confirm the names with a qualified label reviewer or FDA before you use this layout on a real label.

The incomplete draft

This is the kind of draft that gets written from a menu description instead of the specifications:

Ingredients: Crust (enriched flour, water, oil, yeast, sugar, salt), pizza sauce, mozzarella cheese, mushrooms, green bell peppers.

Contains: wheat, milk.

Checked against the ledger, it has eight problems:

Look at the last row. A supplier "Contains" checklist would have caught the soy if someone had read the crust spec. It wouldn't have caught problems 1, 2 and 4 to 7, which leave the ingredient statement incomplete.

A conditional teaching draft

Here's the same pizza with every traced ingredient in place, using the parenthetical method. It depends on the unverified names above, and it isn't approved label text.

Ingredients: Pizza crust (enriched wheat flour [wheat flour, niacin, reduced iron, thiamine mononitrate, riboflavin, folic acid], water, soybean oil, yeast, sugar, salt, soy lecithin), low-moisture part-skim mozzarella cheese (pasteurized part-skim milk, cheese cultures, salt, enzymes), pizza sauce (crushed tomatoes [tomatoes, tomato puree, salt, citric acid], olive oil, garlic, salt, oregano), roasted mushrooms (mushrooms, olive oil, salt), green bell peppers.

Contains: wheat, milk, soy.

Where each part of the order comes from:

• Components: the weight on each pizza, 300 g, 150 g, 110 g, 70 g, then 40 g.
• Inside the crust, cheese and crushed tomatoes: the supplier's ingredient statement, in the supplier's order. A label's list has to be in descending order by weight except for a "2 percent or less" group at the end. These made-up statements don't use one, so if they're compliant, their order is by weight. A real supplier statement still needs that check.
• Inside the sauce and mushrooms: your recipe weights. In the sauce, that's 2,000 g, 60 g, 30 g, 20 g, then 6 g.
• "Contains": wheat from the flour, milk from the cheese, soy from the lecithin. The soybean oil isn't the reason soy is there, because the spec says it's highly refined. Soy would still be there if the oil were left out.

This is a teaching draft, not a ready-to-print label. Besides the name question above, a real label also needs a product name, net quantity, the name and place of business and, for most foods, Nutrition Facts. Those are covered in FDA's Food Labeling Guide, not here.

Why not the dispersed method here

The second method has the same name condition, and it also needs the weight of every ingredient in the finished pizza. You know some of them. Each pizza gets 110 g of the 2,116 g sauce batch, which works out to about 103.97 g crushed tomatoes, 3.12 g olive oil, 1.56 g garlic, 1.04 g salt and 0.31 g oregano.

Salt shows the problem. It's in the crust, the cheese, the crushed tomatoes, the sauce and the mushrooms. To place "salt" once in a dispersed list you need the total from all five. Only the sauce's own salt is known. The supplier labels give order, not amounts, and roasting changes the mushroom weights. So the dispersed method stops here unless your suppliers give you percentages in writing. Never estimate weights from where an ingredient sits on a supplier's label.

Situations to check before you approve the label

Checklist before you sign off a frozen-pizza label

1. List every component on the pizza, including oils, seasonings and anything brushed or sprayed on.
2. Record a set weight per pizza for each component, as it goes into the package.
3. For each purchased component, file the supplier's full ingredient statement and "Contains" line word for word, with the spec revision and the date you checked it. This is ledger evidence, not finished label text.
4. For each house component, file the recipe with weights. A sub-recipe gets its own row.
5. For every oil, record its source and whether the spec says it's highly refined. Record the source of any lecithin.
6. Order the components by weight. Inside a house component, order by recipe weight. Inside a purchased component, start from the supplier's order, but stop if the supplier used a "2 percent or less" group.
7. Confirm that each component name qualifies for the declaration method you plan to use. If you can't, stop before using that layout.
8. Work out the "Contains" line from the full trace. If you use one, it names every major allergen in the pizza.
9. Have a second person check the draft against the ledger, line by line.
10. Stop if any spec, weight, oil source, lecithin source, name question or "2 percent or less" question is unresolved.
11. When a supplier, spec or recipe changes, update the ledger and the label before the changed component goes on a pizza. Update the ingredient text on your website from the same statement.

What this answer doesn't cover

This explains how FDA's ingredient statement and allergen rules apply to a non-meat frozen pizza sold through other shops or online, as of October 4, 2026. It isn't a complete labeling checklist, and it isn't legal advice. It doesn't settle whether particular component names qualify for FDA's parenthetical method, or how a supplier's "2 percent or less" group carries into your label. It doesn't cover manufacturing permits, food safety, freezing or shelf life, Nutrition Facts or claims, or "may contain" statements. It also doesn't cover how your state applies these rules. The FDA guidance cited is nonbinding; the statute and regulations are the requirements. We didn't find FDA guidance specific to restaurants making frozen pizza for other retailers. Have the final label reviewed by someone qualified, and ask your state agency about the rest.

For the kitchen side of allergens, start with our food-safety and allergen starter.

Sources

• FDA, Saint Francis Apizza LLC company announcement (company date October 1, 2026; FDA posted October 3, 2026): https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/saint-francis-apizza-llc-issues-voluntary-recall-its-frozen-pizzas-missing-sub-ingredients-label-soy
• 21 CFR 101.4, Food; designation of ingredients (eCFR, current): https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/section-101.4
• 21 CFR 101.100, Food; exemptions from labeling (eCFR, current): https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/section-101.100
• 21 CFR 133.158, Low-moisture part-skim mozzarella and scamorza cheese (eCFR, current): https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-133/section-133.158
• 21 CFR 137.165, Enriched flour (eCFR, current): https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-137/section-137.165
• 21 U.S.C. 343, FD&C Act section 403(i) and (w): https://www.govinfo.gov/content/pkg/USCODE-2023-title21/html/USCODE-2023-title21-chap9-subchapIV-sec343.htm
• 21 U.S.C. 321(qq), definition of "major food allergen": https://www.govinfo.gov/content/pkg/USCODE-2023-title21/html/USCODE-2023-title21-chap9-subchapII-sec321.htm
• FDA, Questions and Answers Regarding Food Allergens (Edition 5), January 2025, questions D.1, D.6, D.8, D.9 and D.16: https://www.fda.gov/media/117410/download
• FDA, A Food Labeling Guide, ingredient lists questions 2 and 15 and allergen question F1: https://www.fda.gov/media/81606/download
• FDA, Food Labeling & Nutrition: https://www.fda.gov/food/food-labeling-nutrition
• FDA, Food Allergies: https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods/food-allergies
• FDA, Inventory of Petitions Received under 21 U.S.C. 343(w)(6) for Exemptions from Food Allergen Labeling: https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods/inventory-petitions-received-under-21-usc-343w6-exemptions-food-allergen-labeling
• USDA FSIS, Elimination of the Pizza with Meat or Sausage Standards, 68 FR 44859 (July 31, 2003): https://www.federalregister.gov/documents/2003/07/31/03-19505/definitions-and-standards-of-identity-or-composition-elimination-of-the-pizza-with-meat-or-sausage