FDA has defined "sugar free", "no added sugar" and "reduced sugar", and it hasn't defined "low sugar". Nutrient claims can only be made the way the rules define them, so "low sugar", "low in sugar" and "lightly sweetened" as a level aren't available. Sugar free means less than 0.5 grams of sugars per reference amount, and a statement that the food isn't low calorie unless it is. No added sugar means nothing that adds sugar went in, including concentrated fruit juice. Reduced sugar means 25% less than the regular version, with the comparison printed. In the example below, a Michigan preserves maker works out what its lower-sugar cherry spread can say.
The short version
- "Low sugar" isn't defined by FDA, so it can't be used as a claim.
- Sugar free: under 0.5 g per reference amount, with the calorie statement.
- No added sugar: no sugars added, and no fruit juice concentrate either.
- Reduced sugar: 25% less than the regular version, with the comparison.
- Any claim brings a Nutrition Facts panel.
- A lower-sugar jam may not meet the standard for jam or preserves.
- TaroStack keeps each recipe by weight, so the sugar in a batch is the recipe's. More below.
The claims
| Claim | The test | What else the label needs |
|---|---|---|
| Low sugar | Not defined | Not allowed |
| Sugar free | Under 0.5 g per reference amount and serving | Not a reduced calorie food, not a low calorie food, or not for weight control, unless it is |
| No added sugar | No sugars or sugar-containing ingredients added, including juice concentrate | Not low or reduced calorie, unless it is, and a pointer to the Nutrition Facts |
| Reduced sugar | 25% less than a reference food | The reference food, the percentage and the grams of both |
Fruit's own sugar counts toward sugars, so most fruit spreads can't be sugar free. Every condition of no added sugar, worked through, is in no added sugar label. How a jam's name depends on its sugar is in standard of identity food, and what a jar costs in how to price jam.
The rules
| Rule | Where |
|---|---|
| Only defined claims | A nutrient content claim may be made only as the regulations define it (21 CFR 101.13(b)) |
| Sugar free | Under 0.5 g of sugars per reference amount and serving, with the calorie statement (21 CFR 101.60(c)(1)) |
| No added sugar | No sugars added, and no ingredient with added sugars such as jam, jelly or concentrated fruit juice (21 CFR 101.60(c)(2)) |
| Reduced sugar | At least 25% less per reference amount than a reference food, with the comparison (21 CFR 101.60(c)(5)) |
This is general information, not legal advice.
An example: three cherry products
Old Mission Preserves, the made-up preserves maker in Traverse City, Michigan, I use in these examples, wanted "low sugar" on a new cherry spread. Per tablespoon, the reference amount for jams:
| Product | Sugars per tbsp | Against the preserves | What it can say |
|---|---|---|---|
| Tart cherry preserves, the regular | 10 g | No sugar claim | |
| Cherry fruit spread, less sugar | 6 g | 40% less | Reduced sugar, with the comparison |
| Cherry spread, apple juice concentrate | 7 g | 30% less | Reduced sugar; not no added sugar |
"Low sugar" was off the table for both. The less-sugar spread says "Reduced sugar: 40% less sugar than our tart cherry preserves. 6 g vs 10 g per tablespoon." The spread sweetened with apple juice concentrate can't say no added sugar, because juice concentrate counts. Neither has enough sugar to meet the standard for preserves, so both are called fruit spread, in jam labeling requirements.
Get the checker
Download the sugar claim checker. One sheet: each product, its sugars per reference amount, the regular version's sugars, and whether any sugar or juice concentrate is added; the reduction and the claims it can carry 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 numbers are right for the recipe tested. Riper cherries carry more sugar, a batch made with the regular sugar by habit, or a new juice concentrate changes the sugars while the jar still says reduced sugar.
How TaroStack does it
TaroStack keeps each recipe by weight, so the sugar in a batch is the recipe's sugar.
Recipes by weight. Each spread is its own recipe, with its ingredients by weight.
Batches by lot. Each batch records which ingredient lots it used and how many jars it filled.
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 |
| Sugar 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.