Industry guide

Food rotation labels your whole kitchen can read

A practical guide to date marking, FIFO, day-color keys and allergen labels for restaurants, school and hospital kitchens, bakeries and small food producers.

Where labeling goes wrong

Undated containers

Under FDA Food Code 3-501.18, ready-to-eat TCS food in a container without a date or day must be thrown out, even if it is fine [5]. Why it matters: FDA observers found the date-marking item out of compliance at least once in 64% of full-service restaurants studied in 2017-2018 [14][15].

A color code nobody wrote down

The Food Code allows day-of-week colors, but only if the system is disclosed to the inspector on request [4]. If red means "made Monday" to the morning crew and "toss Monday" to the night crew, the color is worse than no color.

Combined foods get a fresh date

Monday's chicken mixed into Wednesday's salad keeps Monday's date: the earliest-prepared ingredient sets the clock [3].

The clock is lost in the freezer

Refrigerated time before freezing and after thawing both count toward the 7 days [6]; a label that only says "frozen" can't show what's left.

Unlabeled working containers

Bulk bins of flour, sugar, oils and spices need the food's common name unless the food is unmistakable, like dry pasta [8].

Labels that fight the dish room

Masking tape leaves residue on reusable tubs; labels that peel off in a walk-in leave mystery food.

Build your color-code system

  1. Decide what gets dated (kitchen manager, once). Ready-to-eat, time/temperature control for safety (TCS) food held cold over 24 hours gets a consume, sell or discard date, at most 7 days at 41°F or below; prep day is Day 1 [2]. Opened commercial containers count from the day opened [2]; some plant-made items, such as hard cheeses, are exempt [11]. Confirm which Food Code edition your jurisdiction adopted [1].
  2. Pick one meaning for color, and write it down. There is no single mandated day-color standard: the Food Code allows color marks but assigns none, and FDA prescribes no label format [4][12]. Choose whether color marks the prep day or the discard day, and post the key on the walk-in door.
  3. Write the date, not just the color. Color gives the day at a glance; the written item, date and initials settle questions [12].
  4. Match the label to the container. Dissolvable: reusable pans, tubs and lids that go through the dish room; they wash off instead of being scraped. Removable: freezer storage and containers reused without soaking; peels cleanly. Permanent: items that leave your kitchen: grab-and-go, wholesale packs, delivery.
  5. Label cook-chill and thaw steps. Write cook date and cooling start time on cooked food going into the cooler; it must reach 70°F within 2 hours and 41°F within 6 hours total [9]. Freezing: note days already used. Thawing: write the thaw date and a discard date using only the days left [5][6].
  6. Identify allergens in storage. Mark prepped items that contain any of the nine major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame [13]. Use one allergen label style and a designated shelf or bin.
  7. Rotate first in, first out. The first batch stored is the first used [7]: new product goes behind the old.

Example day-color key (yours may differ; post it):

Color-code key

Color Meaning Where it goes Product
Red Prepared Monday Lid edge 1" Round Day of the Week Labels
Yellow Prepared Tuesday Lid edge 3/4" x 500" Removable Tape Variety Pack
Green Prepared Wednesday Lid edge 1" Removable Color-Code & Labeling Tape
Dark blue Prepared Thursday Lid edge 1" Removable Color-Code & Labeling Tape
Black Prepared Friday Lid edge 1" Round Day of the Week Labels
Orange Prepared Saturday Lid edge 1" Removable Color-Code & Labeling Tape
White Prepared Sunday Lid edge 1" Removable Color-Code & Labeling Tape
Allergen label Contains a major food allergen Front of container, allergen shelf Dissolvable Allergen Alert Labels, 2" x 3"
Diet dot Gluten free, vegan or dairy free Lid of finished item 1" Imprinted Food Dots

QA/QC: keep it working

  • Owner: the person in charge on each shift checks dates; the kitchen manager owns the key and the training.
  • Daily (opening and close): walk the coolers. Anything undated or past its discard day goes [5]. Fix any color that doesn't match the key; combined items carry the oldest date [3].
  • Weekly: spot-check five containers per cooler for item, date, color and initials; check bulk bins for names [8]; restock labels so nobody reaches for masking tape.
  • Relabel, don't overlabel: when food is portioned, rewrapped or thawed, remove the old label so each container shows one date.
  • New staff: teach the posted key on day one, plus allergen awareness: the major allergens and reaction symptoms [10].
  • Inspection ready: keep the color key, cooling logs and your date-marking procedure in one binder you can hand the inspector [4].

Printable checklist

Kitchen Date Marking & Rotation Checklist

Post this by the walk-in and check it at every shift change.

Date marking

  • Every ready-to-eat TCS item held over 24 hours is dated
  • Prep or open day counted as Day 1; discard by Day 7
  • Combined foods carry the oldest ingredient's date
  • Opened commercial containers marked with the open date
  • Nothing past its use-by or discard date in any cooler

Color key and rotation

  • Color key posted on walk-in door and in manager binder
  • Key says whether color means prep day or discard day
  • New product placed behind or below older product
  • Only one date label per container

Freeze, thaw, cook-chill

  • Freezer labels show prep date and days already used
  • Thawed items show thaw date and new discard date
  • Cooling food labeled with cook date and cooling start time
  • Cooling log filled in for every batch

Allergens and storage

  • Prepped items with major allergens carry an allergen label
  • Allergen items stored low or in a marked bin
  • Bulk bins labeled with the food's common name
  • Dissolvable labels on dish-room containers; no masking tape

Our color key

ColorMeaningOwner
 
 
 
 
 
 
Download PDF

Recommended products

Dissolvable Food Rotation Use By Labels, 1" x 2"

writable use-by labels for pans and tubs that wash off in the dish room.

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Dissolvable Allergen Alert Labels, 2" x 3"

check boxes for all nine major allergens plus item, prep date, use-by and initials.

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1" Round Day of the Week Labels

the day printed on a colored dot, so the color and the word agree.

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1" Removable Color-Code & Labeling Tape, 60 yds

writable tape in 22 colors for day keys on lids and racks.

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3/4" x 500" Removable Tape Variety Pack

several colors at once to set up a full day-color key.

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Removable Freezer-Safe Best If Used By Labels, 1.5"

for frozen and refrigerated containers that are reused.

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1" Permanent Made On / Sell By Dots

for grab-and-go and packaged items that leave the kitchen.

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1" Imprinted Food Dots (Gluten Free, Vegan, Dairy Free)

marks special-diet items on finished containers.

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Frequently asked questions

Is there a required color for each day of the week?

No. The Food Code allows color-coded marks but assigns no colors [4][12]. Write your key down and show it to the inspector on request.

Does the day food is made count as Day 1?

Yes. Prep day is Day 1; for opened commercial containers, the day opened is Day 1 [2].

Does freezing stop the 7-day clock?

Frozen time doesn't count; refrigerated time before freezing and after thawing does [5][6].

Is the FDA Food Code the law where I am?

It is a model code that agencies adopt, sometimes as an older edition or with changes [1]. Ask your health department which version applies.

When should I use dissolvable labels instead of removable ones?

Dissolvable for anything that goes through the dish room; removable for freezer storage and containers you peel and reuse dry.

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Sources
  1. FDA Food Code 2022, Preface: “This model is offered for adoption by local, state, and federal governmental jurisdictions”
  2. FDA Food Code 2022, § 3-501.17(A)-(B): “refrigerated, READY-TO-EAT, TIME/TEMPERATURE CONTROL FOR SAFETY FOOD prepared and held in a FOOD ESTABLISHMENT 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." and "(1) The day the original container is opened in the FOOD ESTABLISHMENT shall be counted as Day 1”
  3. FDA Food Code 2022, § 3-501.17(C): “that is subsequently combined with additional ingredients or portions of FOOD shall retain the date marking of the earliest-prepared or first-prepared ingredient.”
  4. FDA Food Code 2022, § 3-501.17(D)(4): “Using calendar dates, days of the week, color-coded marks, or other effective marking methods, provided that the marking system is disclosed to the REGULATORY AUTHORITY upon request.”
  5. FDA Food Code 2022, § 3-501.18(A): “(1) Exceeds the temperature and time combination specified in ¶ 3-501.17(A), except time that the product is frozen; P (2) Is in a container or PACKAGE that does not bear a date or day”
  6. FDA Food Code 2022, Annex 3, §§ 3-501.17/18: “Food which is prepared and held, or prepared, frozen, and thawed must be controlled by date marking to ensure its safety based on the total amount of time it was held at refrigeration temperature, and the opportunity for Listeria monocytogenes to multiply, before freezing and after thawing.”
  7. FDA Food Code 2022, Annex 5: ““First-In-First-Out” (FIFO) means that the first batch of product prepared and placed in storage should be the first one sold or used.”
  8. FDA Food Code 2022, § 3-302.12: “working containers holding FOOD or FOOD ingredients that are removed from their original packages for use in the FOOD ESTABLISHMENT, such as cooking oils, flour, herbs, potato flakes, salt, spices, and sugar shall be identified with the common name of the FOOD.”
  9. FDA Food Code 2022, § 3-501.14(A): “(1) Within 2 hours from 57ºC (135ºF) to 21ºC (70°F); P and (2) Within a total of 6 hours from 57ºC (135ºF) to 5ºC (41°F) or less.”
  10. FDA Food Code 2022, § 2-103.11(O): “FOOD allergy awareness includes describing FOODS identified as MAJOR FOOD ALLERGENS and the symptoms that a MAJOR FOOD ALLERGEN could cause in a sensitive individual who has an allergic reaction”
  11. FDA Food Code 2022, § 3-501.17(G): “Paragraph (B) of this section does not apply to the following FOODS prepared and PACKAGED by a FOOD PROCESSING PLANT inspected by a REGULATORY AUTHORITY”
  12. FDA National Retail Food Team, Food Code Section 3-501.17 Date Marking fact sheet (2019): “The FDA Food Code does not specify a particular date marking label, nor does it specify that the time the food was prepared be captured on the label.”
  13. FDA, Food Allergies: “The major food allergens are milk, eggs, fish, Crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame.”
  14. FDA, Report on the Occurrence of Foodborne Illness Risk Factors in Fast-Food and Full-Service Restaurants 2017-2018 (June 2023): “"These data items had out-of-compliance percentages of 80%, 69%, and 64%, respectively." (item 8: refrigerated, RTE foods properly date marked, full-service)”
  15. Same report, methodology: “The 80% score should not be interpreted to mean that foods were cooled improperly 80% of the time.”
  16. ReFED, Food Waste by Sector: Foodservice fact sheet (2024 data): “Surplus food from foodservice was valued at $157 billion dollars in 2024." / "That’s equivalent to 14% of foodservice sales.”
  17. O*NET OnLine, Local wages, Food Preparation Workers 35-2021 (BLS 2025 wage data): “"$16.98" (U.S. hourly median)”
  18. U.S. BLS, Employer Costs for Employee Compensation, June 2026: “benefit costs averaged $14.07 and accounted for the remaining 30.0 percent”