Nutrition Labeling of Sample Products

My marketing department had sample bags printed for distribution to consumers.  These bags are marked "not for resale" and will be given away for free.  21CFR109 begins with " products intended for human consumption and offered for sale."  The ingredient list (with allergens) is on the packaging but does anyone know if we need the nutrition panel as well? 

We don't use ingredients statements on our "Lab" samples.

You are sending a "Sample use only" or "For testing only"

I was just researching this for a customer myself. Assuming this is FDA labeling regulations? No, a nutrition panel is not required if not for resale. There is an exemption for that.

Our customer wants to give away sauce samples in small pouches to prospective buyers. There is an FDA exemption for nutrition panel and for principal display panel for the pouches, but I'm not sure about ingredients list. He has proposed using the multi-unit exemption by having the pouches inside a bag with all of the FDA labeling on it, but passing out sample pouches without labeling. I am buried in food labeling guides and unsure now... advice? Must the pouches state "not for retail sale?"