How to Use the “No Sugar Added” Nutrient Content Claim: A Food Manufacturer’s Guide

Online nutrition analysis software, like LabelCalc, makes it easy to see which sugar-related nutrient content claims your food product qualifies for. Photo source: Unsplash user Ben White.

Food manufacturers often ask me for advice about including nutrient content claims, like low-fat or low-calorie, on their products. Recently though, I have been getting a lot of questions about using nutrient content claims related to sugar.

The average American consumes an average of 66 pounds of sugar per year, and that excess sugar consumption is a major contributing factor in heart disease, type 2 diabetes, and obesity. In response to this high sugar intake, the Center for Disease Control is recommending that Americans get no more than 10% of their daily calories from sugar, which equates to about 200 calories in a 2,000 calorie diet.

Given the overconsumption of sugar in this country, it’s no wonder that food manufacturers are interested in providing Americans with low-sugar options. However, the guidelines for sugar nutrient content claims are a little complex. So, in order to help you use these claims confidently and correctly, I’m going to walk you through how to use the “no sugar added” nutrient content claim, as well as other sugar-related claims.

The “No Sugar Added” Nutrient Content Claim and Beyond: Guidelines for Use

There are three categories for sugar nutrient content claims: “sugar-free” claims, “no sugar added” claims, and “reduced sugar” claims. Each one has different FDA requirements, so pay close attention to the differences.

To use the “sugar-free/insignificant source of sugar” claim, your food product must:

• Contain less than 0.5 grams of sugar per serving size and reference amount customarily consumed (RACC).
• Contain less than 0.5 grams per labeled serving for meal and main dish products.
• Contain no added sugar or foods that are known to contain sugar, unless the ingredient is included in the ingredient list and is accompanied by an asterisk and a statement saying something to the effect of, “adds a negligible/insignificant amount of sugar.”
• Must also be labeled as a reduced or low-calorie food; if it isn’t a low-calorie food, you must accompany the claim with a disclaimer along the lines of, “not a low-calorie food.”

To use the “no sugar added” or “without added sugar” claim, your product must meet the following requirements:

• There can be no sugar substitute that contains sugar added to the product (i.e. honey).
• There can be no foods that contain added sugar in the product (i.e. fruit juice).
• The reference food that it provides an alternative for typically contains sugar.
• The package states that it is not a low-calorie food, unless it meets the low-calorie requirements.
• The product does not contain a significant amount of natural sugars.

To use claims such as “reduced sugar,” “less sugar,” or “lower in sugar,” your product must follow these guidelines:

• The product contains at least 25% less sugar per RACC than a similar reference food (i.e. a “regular” version of the product).
• The product package includes a statement that illustrates the discrepancy between the reference food and the product itself (i.e. contains 30% less sugar than our regular fruit snacks) immediately next to the “reduced sugar” claim.
• The product package includes a statement that illustrates how many grams of sugar per serving were in the reference food compared to the food product (i.e. sugar content reduced from 12 grams per serving to 6 grams per serving).
• For meal and main dish products, the sugar content must be reduced by 25% per 100-gram serving compared to a reference food.

Of course, if you are still unsure whether your product qualifies for one of the above claims or need additional guidance, it is a good idea to consult a nutrition labeling expert. They will be able to give you advice as to which claim is best suited to your specific product and make sure you are using it in compliance with the guidelines.

Ways to Reduce Sugar in Manufactured Foods

There are many ways for food manufacturers to reduce the quantity of sugar in their products without sacrificing flavor if they wish to use a sugar-related NCC. Below are a few ways you can accomplish this:

• Replace sugar with calorie-free sweeteners such as Xylitol or stevia.
• Replace sugar content with natural sweeteners, such as honey, maple syrup, or coconut sugar in small quantities.
• Incorporate fruit juices and purees (such as date puree) into your product to lend a naturally sweet taste.
• Incorporate sugar-free ingredients that impart a naturally sweet taste, like cinnamon or vanilla bean.

In short, if you get creative with your recipes, there will be plenty of options for reducing sugar in your product.

The world of NCCs can be confusing, especially when dealing with those related to sugar. That’s why I always recommend you use an online nutritional analysis software that analyzes your recipe and instantly provides you with a list of all the nutrient content claims it qualifies for. With such software on your side, you can decide which claims to use on your product based on your target consumer, and you will save yourself the time and effort of doing all the complicated calculations by hand. This way, whatever claim you end up using, whether it’s “sugar-free” or “no-sugar-added,” you can trust that you are using it in accordance with the FDA’s guidelines.

LabelCalc is an online nutrition analysis software that instantly generates your nutrition facts panel and shows which Nutrient Content Claims your product applies for. To learn more about our FDA-compliant online nutritional analysis software, contact us today.