In FDA regulations, Food labeling, Nutrition facts labels

With the recent keto-diet craze and the ongoing quest to keep things low in total carbohydrate value, consumers have been obsessed with sugar substitutes. While all of these sweeteners make it into the ingredient list, very few impact the macronutrient counts on an actual nutrition label. And then there’s allulose.

Allulose, a monosaccharide, is a fructose-derived sugar-substitute that constitutes about 0.4 total calories per 1 g. It can be found in small amounts in certain fruits as well as wheat. As of April 2019, the FDA had something to say about this sweet ingredient and released an industry guide in regards to food labels. Upon receiving multiple petitions to both include and not include allulose on food labels, the FDA has responded, and in great detail. While the official release states they will exercise discretion in regards to how they evaluate food labels containing allulose, there are a few recommendations provided due to it’s unique chemical breakdown. If you are a food manufacturer who is wondering if citing allulose is necessary, read on for helpful tips provided in the FDA‘s industry guideline.

Allulose is Technically a Carbohydrate

According to the industry guideline posting on allulose at www.fda.gov  :

“Carbohydrate” as a class captures a variety of substances ranging from mono and disaccharides to numerous types of non-digestible carbohydrates, some of which are dietary fibers

According to chemical breakdown, allulose is considered a monosaccharide. Recent documentation drawn up and submitted to the FDA by food lawyers petitioned that allulose should not be considered as a carbohydrate due to the lack of impact on glucose levels upon consumption. The U.S. Food and Drug Administration concluded in their industry guideline that allulose did, in fact, meet the criteria for the classification as a carbohydrate. Despite it’s lack of impact upon blood glucose, it must be cited in the total carbohydrate count on a food label in food products containing this sweetener.

Allulose and Total Sugar Count

Making it onto the total sugar category of a label is more complicated than you may think. Sugar counts are impacted by the digestive process of the sugar itself and if it alters the pH balance of the environment of the mouth, contributing to dental carries (cavities). Total sugar count also alerts the consumer that a particular food product will raise their insulin and blood glucose levels and to what degree.

The digestive process begins in the mouth with the release of saliva that begins breaking down the food for it’s journey into the stomach. When allulose begins the digestive process, it does not alter the pH balance of the mouth below 5.7, and therefore it doesn’t meet the first bit of criteria to be considered for total sugar count on a nutrition facts label. Secondly, allulose ferments or breaks down very poorly in the digestive tract, leaving the body basically intact with only miniscule impact on blood glucose levels. Because of these 2 guidelines used to categorize an ingredient as qualified for total sugar count, allulose does not make the cut.

In regards to added sugars, allulose fell short in fitting that criteria as well. Though it is a sweetener with a small caloric value, due to it’s lack of glucose impact in a normal serving size, it does not meet the criteria for added sugars and does not need to be reflected on a nutrition facts label.

Allulose and Total Calories

The total calories in allulose have been debated not on the legal side of the food industry through petition, but also by analysis on the scientific end conducted by the FDA. In the dietary guidelines released by the U.S. Food and Drug Administration in their industry guideline concerning allulose, total calories have been published in a range of 0.2-0.4 kcal/g. In order to provide the most accurate nutrition information on a food label, the FDA encourages that allulose be added to total calories at an amount of 0.4kcal/g. The reasoning behind this is so that the caloric value is not underestimated in the food products containing this ingredient.

In Summary

If you are a food manufacturer who is considering the creation of a new nutrition label to reflect this sweetener in your nutrition label, it may be worth it to cite in more than just your ingredient list. Though the FDA did state that these dietary guidelines are discretionary as of this point in time, it may be beneficial to cite allulose in total calories in the long run on your nutrition facts panel of your food package. Updating your label with sound nutritional analysis software will ultimately save time and cover your bases in the case that new nutrition regulations are enforced down the line.

LabelCalc is an industry-leading recipe analysis tool used by food manufactures, global retail stores and food entrepreneurs. To get started, see our pricing today.

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