Added Sugars Declarations in Nutrition Facts Labeling is a popular and complicated topic. When it comes to naturally sweet ingredients, such as fruits and vegetables, what needs to be included as “Added Sugar” in the Nutrition Facts panel?
Current Nutrition Facts labeling regulations require a quantitative “Added Sugars” declaration and accompanying percent Daily Value.
“Added Sugars” are defined by the FDA as “added during processing” and include:
• Free mono- and disaccharides (e.g., glucose and sucrose)
• Syrups and honey
• Fruit and vegetable juice concentrates unless diluted (i.e., sufficient free water/moisture is formulated into the product for the concentrate to be made equivalent to a single strength ingredient, based on FDA Code of Federal Regulations’ [CFR] established Brix values for standardized juice)
• Powdered fruit or vegetable juices in excess of reconstituted single-strength juice
FDA does consider foods sweetened with concentrated fruit or vegetable juices—when added as an ingredient to a product but not reconstituted to single-strength juice during processing to be sugar-sweetened foods.
“Added Sugars” do not include:
• Fruit or vegetable juice concentrates used towards the total juice percentage label declaration or for Brix standardization
• Whole fruit, fruit pieces, pulps and purees, because they are nutrient-rich and maintain the basic properties of a fruit when used as an ingredient
• Dried fruits with no added sugar, because they are essentially dehydrated whole fruit that retains the nutrients and other components of whole fruit (e.g., diced dried apples). However, if additional sugar is added, it must be declared on the label as added sugars
• Fruit juice concentrates used in the fruit component of jellies, jams or preserves standard of identities or the fruit component of fruit spreads
• Whole fruits, pieces of fruit, dried fruit, fruit or vegetable purees (single strength or concentrated), fruit pulps, single-strength juices, fruit and vegetable pastes, and fruit and vegetable powders that are not made from fruit or vegetable juices
If the initial juice ingredient—whether diluted, 100% or concentrated—is further concentrated during production due to moisture loss, such as through drying or baking, further calculations are required. (See https://www.fda.gov/media/117402/download)
FDA’s Industry Guidance on Added Sugars Labeling gives sweetened, dried fruit and sweetened flavorings as examples of other ingredient components to review for gram contributions when totaling added sugars for Nutrition Facts labeling in a finished product serving. The review also includes relevant processing, such as dilution of a concentrated fruit or vegetable juice or fermentation.
Allulose & Erythritol: Sweetener Exceptions
Although erythritol is compositionally a carbohydrate (a teaspoon of erythritol is about 4 grams), for nutrition labeling purposes, FDA recognizes erythritol as possessing 0.2 kilocalories per gram, because it is not metabolized during digestion. Allulose’s caloric value of 4 calories per gram must be included in the Nutrition Facts carbohydrate declaration, but FDA is exercising enforcement discretion for exclusion from the Total Sugars amount, pending future rulemaking regarding amendment of the Total Sugars definition. FDA concludes that allulose is virtually unmetabolized and should not be included in the Added Sugars declaration or Percent Daily Value.
Sugar and Content Labeling Claims
Because there is no Daily Reference Value for Total Sugars, there is no Percent Daily Value and, therefore, no FDA-established regulations defining “Low Sugar” or “Low in Sugar.” This would make the use of such a label claims violation. However, relative claims can be made using the term “Lower,” if in compliance with comparative criteria, as well as declaration and disclosure requirements detailed in the CFR for the phrases: “Lower in Sugar,” “Lower Sugar,” “Reduced Sugar,” “Reduced in Sugar,” “Sugar Reduced” and “Less Sugar.”
Also permissible are the claims “Sugar Free,” “Free of Sugar,” “No Sugar,” “Zero Sugar,” “Without Sugar,” “Sugarless,” “No Added Sugar,” “Without Added Sugar” and “No Sugar Added” when regulatory compliance is met. “Unsweetened” and “No Added Sweeteners” can be used as factual statements. On the other hand, “Low Carb” has never been established (i.e., defined) by the FDA. When an undefined claim is used, the product is considered misbranded, concluded Swann.
— Lauren Swann, MS, RD, LDN, Concept Nutrition, Inc.
FDA Industry Guides:
• Nutrition and Supplement Facts Labels: Questions and Answers Related to Added Sugars
• Declaration of Allulose and Calories from Allulose on Nutrition and Facts Labels
Code of Federal Regulations:
• 21 CFR 101.9 – Erythritol and Nutrition Labeling
• 21 CFR 101.60 – Sugar Content Claims
See also the presentation Formulating with Whole Fruit Ingredients given by Kristen Sparkman, CuliNex at the 2021 Sweetener Systems Premium Webinar.