In case anyone finds this interesting
here's a screenshot of the nutrient labeling exemption application page. At the bottom, there's another statement that if the total number of units is less than 10,000 and the business employs less than 10 people, an exemption application is not even necessary...for
food sales.
Since the Dietary Supplement Health and Education Act (DSHEA, 1994) defined dietary supplements as a category of food, I am pretty sure small kava businesses that act as distributors or packers (but not importers) are qualified to apply for this exemption. To be 100% sure, I emailed the FDA's small business unit. I'll report back when I find out more.
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