"Low calorie" means 40 calories or less per reference amount, FDA's standard serving for that kind of food. Foods with small reference amounts, 30 grams or 2 tablespoons or less, also have to meet it per 50 grams, and that's where dressings, sauces and dips get caught: a salad dressing's reference amount is 30 grams, so a low calorie dressing needs 40 calories or less per 50 grams, about 24 calories a serving. "Calorie free" means under 5 calories. "Reduced calorie" means at least 25% fewer than a named comparison food, with the comparison and the numbers on the label. A food that's low in calories without being made that way, like celery, says so for all foods of its kind, "celery, a low calorie food". And any of these claims brings a Nutrition Facts panel, even for a business small enough to skip one otherwise. In the example below, a New Hampshire dressing maker learns why its first low calorie vinaigrette didn't qualify.
The short version
- Low calorie: 40 calories or less per reference amount.
- Small reference amounts (30 g or 2 tbsp or less): also 40 calories or less per 50 g.
- A salad dressing at 30 g needs about 24 calories a serving to be low calorie.
- Calorie free: under 5 calories per serving.
- Reduced calorie: at least 25% fewer than a named food, with the comparison.
- Naturally low foods say so for all foods of their kind.
- TaroStack keeps each recipe by weight, so the oil in a batch is the recipe's oil. More below.
The claims
| Claim | Limit per reference amount | Small reference amounts |
|---|---|---|
| Calorie free | Under 5 calories | Same |
| Low calorie | 40 calories or less | Also 40 or less per 50 g |
| Reduced calorie, fewer calories | At least 25% fewer than a reference food | Same, with the comparison |
Sodium and fat claims follow the same pattern, in low sodium claim and fat free claim.
The rules
| Rule | Where |
|---|---|
| Calorie claims | Calorie free, low calorie with the per-50-gram test for small reference amounts, and reduced calorie (21 CFR 101.60(b)) |
| Reference amounts | Dressings for salads, 30 g (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 vinaigrettes
Monadnock Dressing Co., the made-up dressing maker in Keene, New Hampshire, I use in these examples, was asked by a grocer for a low calorie vinaigrette. Per 30 g serving, about 2 tablespoons:
| Vinaigrette | Calories a serving | Per 50 g | Claim that fits |
|---|---|---|---|
| Classic maple | 140 | 233 | None |
| Lighter maple | 90 | 150 | Reduced calorie: 36% fewer than the classic |
| Low calorie, first try | 35 | 58 | Reduced calorie only: misses low calorie per 50 g |
| Low calorie | 20 | 33 | Low calorie |
The first try, at 35 calories a serving, met 40 per serving but not per 50 grams. The kitchen cut the oil further, thickening with a little xanthan gum and more apple cider, to reach 20 calories a serving, which made "low calorie". The lighter maple went out as "reduced calorie, 36% fewer calories than our classic maple vinaigrette, 140 to 90 calories a serving". Both carry Nutrition Facts panels. The dressing business's numbers are in salad dressing business plan.
Get the checker
Download the calorie claim checker. One sheet: each product's reference amount, whether it's small, calories per reference amount, and a reference food's calories; calories per 50 grams 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 batch with a generous pour of oil, and the low calorie bottles aren't, which only the batch record shows.
How TaroStack does it
TaroStack keeps each recipe by weight, so the oil in a batch is the recipe's oil.
Recipes by weight. Each vinaigrette is its own recipe, with its oil, vinegar and maple by weight.
Batches by lot. Each batch records which ingredient lots it used and how many bottles 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 | From the recipe and batch |
| 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.