"Fat free" on a label means less than half a gram of fat per reference amount, FDA's standard serving for that kind of food, and per labeled serving, with no fat ingredient added unless it's flagged as adding a trivial amount. A food that's naturally fat free, like a gummy candy, can say so only in a way that covers all foods of its kind, such as "gummy candy, a fat free food". "Low fat" means 3 grams or less, and for foods with small reference amounts, 30 grams or 2 tablespoons or less, the limit applies per 50 grams too, which catches snacks: popcorn's reference amount is 30 grams. "Reduced fat" means at least 25% less than a named comparison food, with the comparison on the label. "95% fat free" and the like are allowed only on foods that are low fat. And any claim brings a Nutrition Facts panel, even for a business small enough to skip one otherwise. In the example below, a Columbus popcorn maker finds out which of its lighter popcorns can say what.
The short version
- Fat free: under 0.5 g per reference amount and serving, no added fat unless flagged.
- Naturally fat free foods say so for all foods of their kind, not as if the brand were special.
- Low fat: 3 g or less per reference amount, and per 50 g for small reference amounts.
- Snacks, popcorn included, have a 30 g reference amount, so the 50 g test applies.
- Reduced fat: at least 25% less than a named food, with the comparison.
- Percent fat free only on low fat foods.
- TaroStack keeps each recipe by weight, so the oil in a batch is the oil in the recipe. More below.
The claims
| Claim | Limit per reference amount | Small reference amounts |
|---|---|---|
| Fat free | Under 0.5 g, no fat ingredient unless asterisked | Same |
| Low fat | 3 g or less | Also 3 g or less per 50 g |
| Reduced fat, less fat | At least 25% less than a reference food | Same, with the comparison |
| Percent fat free | Only if low fat | Same |
| 100 percent fat free | Fat free, under 0.5 g per 100 g, no added fat | Same |
Sodium follows the same pattern, in low sodium claim, and the nutrition panel a claim brings in how to make a nutrition label.
The rules
| Rule | Where |
|---|---|
| Fat claims | Fat free, low fat, reduced fat and percent fat free, with the per-50-gram test for small reference amounts (21 CFR 101.62(b)) |
| Reference amounts | Snacks, popcorn included: 30 g (21 CFR 101.12) |
| The exemption | The small business exemption from nutrition labeling only applies if the food bears no nutrition claims (21 CFR 101.9(j)(1)) |
This is general information, not legal advice.
An example: four popcorns
Copper Kettle Popcorn, the made-up popcorn maker in Columbus, Ohio, I use in these examples, was asked by a grocer for a lighter kettle corn. Per 30 g serving:
| Popcorn | Fat a serving | Per 50 g | Claim that fits |
|---|---|---|---|
| Kettle corn | 6.0 g | 10.0 g | None |
| Light kettle corn | 4.5 g | 7.5 g | Reduced fat: 25% less than the kettle corn |
| Air-popped, lightly sweetened | 2.4 g | 4.0 g | Reduced fat only: low fat per serving, not per 50 g |
| Air-popped, sea salt | 1.5 g | 2.5 g | Low fat, and "95% fat free" |
The lightly sweetened air-popped corn looked low fat at 2.4 g a serving, but at 4.0 g per 50 g it misses, so its bag says "reduced fat, 60% less fat than our kettle corn" with the numbers. The sea salt version is low fat both ways and can carry "95% fat free" in the same type size as the number. Each claim brought a Nutrition Facts panel onto the bag. How popcorn is packaged for stores is in how to package popcorn for sale.
Get the checker
Download the fat claim checker. One sheet: each product's reference amount, whether it's small, fat per reference amount, whether fat was added, and a reference food's fat; the fat per 50 grams, the percent fat free figure and which claims fit fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The claim is true for the recipe that was analyzed. A kettle run with a heavier pour of oil, and the reduced fat bags aren't, which only the batch record can show.
How TaroStack does it
TaroStack keeps each recipe by weight, so the oil in a batch is the oil in the recipe.
Recipes by weight. The light kettle corn is its own recipe, with its oil and sugar by weight, separate from the regular.
Batches by lot. Each batch records which oil and kernel lots it used, and how much it made.
Recalls. If a batch was made from 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 used in a batch | Not recorded | Batches by lot |
| Who got a wrong batch | Invoices | 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.
