Plant foods have no cholesterol, so "cholesterol free" looks like a free claim for a nut butter, an oil or a vegan cookie. It isn't, quite. FDA's definition has three parts: under 2 mg of cholesterol per reference amount and serving, no ingredient people expect to carry cholesterol, and 2 grams or less of saturated fat per reference amount. That last part rules out some plant foods: peanut butter and anything with coconut or palm oil can have too much saturated fat to make the claim, even with no cholesterol at all. A food that never had cholesterol also has to say so for all foods of its kind, not as if your brand had done something: "almond butter, a cholesterol-free food". And a food with more than 13 grams of fat per reference amount, serving, or per 50 grams for small reference amounts has to disclose its fat next to the claim, as in "canola oil, a cholesterol-free food, contains 14 g of fat per serving". Like any claim, it brings a Nutrition Facts panel. In the example below, a New Jersey cottage food maker checks four nut butters.
The short version
- Cholesterol free: under 2 mg per reference amount and serving.
- And 2 g or less of saturated fat per reference amount, which rules out some plant foods.
- No ingredient people expect to carry cholesterol, unless flagged as trivial.
- Naturally free foods say so for all foods of their kind: "almond butter, a cholesterol-free food".
- Over 13 g of fat: disclose the fat per serving next to the claim.
- Any claim means a Nutrition Facts panel.
- TaroStack keeps each recipe by weight, so the coconut in a batch is the recipe's coconut. More below.
The conditions
| Condition | Limit |
|---|---|
| Cholesterol | Under 2 mg per reference amount and serving |
| Ingredients | None generally understood to contain cholesterol, unless asterisked as trivial |
| Saturated fat | 2 g or less per reference amount |
| Naturally free | Worded for all foods of its kind |
| Total fat over 13 g | Per reference amount, serving, or per 50 g for small reference amounts: disclose the fat per serving |
The fat and healthy claims are in fat free claim and healthy claim FDA rules.
The rules
| Rule | Where |
|---|---|
| Cholesterol free | Under 2 mg per reference amount and serving; no cholesterol ingredients unless asterisked; 2 g or less saturated fat; naturally free foods labeled as all foods of their type; fat disclosure over 13 g (21 CFR 101.62(d)(1)) |
| Reference amount | Nut and seed butters, 2 tablespoons (21 CFR 101.12) |
| The exemption | The small business exemption from nutrition labeling applies only if the food bears no nutrition claims (21 CFR 101.9(j)(1)) |
This is general information, not legal advice.
An example: four nut butters
Pinelands Pantry, the made-up cottage food maker in Hammonton, New Jersey, I use in these examples, wanted "cholesterol free" on its nut butter jars. Per 2-tablespoon, 32 g serving:
| Butter | Cholesterol | Saturated fat | Total fat | Claim |
|---|---|---|---|---|
| Almond butter | 0 mg | 1.2 g | 18 g | "Almond butter, a cholesterol-free food, contains 18 g of fat per serving" |
| Maple almond butter | 0 mg | 1.1 g | 16 g | "Maple almond butter, a cholesterol-free food, contains 16 g of fat per serving" |
| Peanut butter | 0 mg | 2.6 g | 16 g | None: saturated fat over 2 g |
| Coconut almond butter | 0 mg | 5.8 g | 19 g | None: saturated fat over 2 g |
The almond butters qualify, but the claim had to grow: the "a cholesterol-free food" wording, since almonds never have cholesterol, and the fat line, since 18 grams is over 13. The peanut and coconut almond butters, with no cholesterol at all, can't make the claim because of their saturated fat. The Pantry decided the long version wasn't worth a Nutrition Facts panel it otherwise doesn't need, and left the claim off. The cottage food rules it sells under are in New Jersey cottage food law.
Get the checker
Download the cholesterol free checker. One sheet: each product's reference amount, cholesterol, saturated fat and total fat, and whether it's naturally without cholesterol; whether it can say cholesterol free, the wording and the fat disclosure fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
A claim like this depends on the recipe staying put. A batch of almond butter made with a scoop of coconut oil to loosen it, and the claim on those jars is wrong, which only the batch record shows.
How TaroStack does it
TaroStack keeps each recipe by weight, so the coconut in a batch is the recipe's coconut.
Recipes by weight. Each butter is its own recipe, with its nuts, oil and maple by weight.
Batches by lot. Each batch records which ingredient lots it used and how many jars it made.
Recalls. If a batch went out with the wrong recipe, one report shows every customer who got it.
| The job | Notebook | In TaroStack |
|---|---|---|
| Which recipe a batch followed | Remembered | Each batch from its recipe |
| Oil added to a batch | Not recorded | From the recipe and batch |
| Who got a wrong batch | Market memory | One recall report |
Recipes, batches and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.