"No sugar added" is an FDA-defined claim, with conditions. You can use it only if no sugars, and no ingredients that contain sugars standing in for them, such as jam, jelly or concentrated fruit juice, went in; processing didn't raise the sugar; the food it replaces normally has added sugar; and the label says the food isn't low calorie and points to the nutrition panel. "Sugar free" is stricter: under half a gram of sugars per serving, plus a calorie statement. "Reduced sugar" means at least 25% less than a named comparison food, with the comparison on the label. And "low sugar" isn't allowed at all, because FDA has never defined it, and a claim about how much of a nutrient is in a food can only use defined terms. One more catch for small makers: any of these claims means a Nutrition Facts panel, even for a business small enough to skip one otherwise. In the example below, a Washington apple butter maker checks four versions.
The short version
- No sugar added: no sugars or sugar-containing ingredients added, juice concentrate included.
- The food it replaces has to normally contain added sugar, and the label says it isn't low calorie.
- Sugar free: under 0.5 g of sugars per serving, and a calorie statement.
- Reduced sugar: at least 25% less than a named food, with the comparison on the label.
- "Low sugar" isn't a defined term, so it can't be used.
- Any claim means a Nutrition Facts panel, even if you're exempt otherwise.
- TaroStack keeps each recipe by weight, so the sugar in a batch is the sugar in the recipe. More below.
The claims
| Claim | What it takes |
|---|---|
| No sugar added, without added sugar | No sugars or sugar-containing ingredients added; sugars not raised by processing; replaces a food that normally has added sugar; "not a low calorie food" and a pointer to the nutrition panel |
| Sugar free, zero sugar, no sugar | Under 0.5 g sugars per reference amount and serving; no sugar ingredients unless asterisked; a low or reduced calorie claim, or "not a reduced calorie food" |
| Reduced sugar, less sugar | At least 25% less sugar than a reference food, naming it and the difference |
| Low sugar | Not defined; not allowed |
| Unsweetened | A factual statement allowed for foods with a lot of natural sugar, such as juice |
How the nutrition panel works is in how to make a nutrition label, and the exemption a claim takes away in nutrition label small business exemption.
The rules
| Rule | Where |
|---|---|
| Sugar claims | Sugar free, no added sugar and reduced sugar, with their conditions (21 CFR 101.60(c)) |
| Defined terms only | A claim about the level of a nutrient follows the regulations that define it (21 CFR 101.13(b)) |
| 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 apple butters
Columbia Orchard Kitchen, the made-up cottage food maker in Wenatchee, Washington, I use in these examples, makes apple butter, and market customers kept asking for one without sugar. Per tablespoon:
| Version | Sugars | What went in | Claim allowed |
|---|---|---|---|
| Classic | 10 g | Apples, cider, cane sugar, spices | None |
| Unsweetened | 5 g | Apples, cider, spices | No sugar added, with the statement |
| Sweetened with apple juice concentrate | 9 g | Apples, juice concentrate, spices | None: concentrate counts as added sugar |
| Lighter | 7 g | Less cane sugar | Reduced sugar: 30% less than the classic |
The kitchen launched the unsweetened version, labeled "No sugar added. Not a low calorie food. See nutrition information for sugar and calorie content." The claim brings a Nutrition Facts panel with it, which the kitchen hadn't needed before, so it paid for a recipe analysis. The juice concentrate idea was dropped, since it would have tasted sweet and still couldn't use the claim. "Low sugar" never made it onto a draft. The cottage food rules the kitchen sells under are in Washington cottage food laws.
Get the checker
Download the sugar claim checker. One sheet: each product's sugars per reference amount, whether sugars or sugar-containing ingredients went in, whether the food it replaces normally has added sugar, and a reference food's sugars; whether it can say sugar free, no sugar added or reduced sugar fills 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 on the label. If someone grabs the sweetened cider for an unsweetened batch, the label on those jars stops being true, and only the batch record shows which jars.
How TaroStack does it
TaroStack keeps each recipe by weight, so the sugar in a batch is the sugar in the recipe.
Recipes by weight. The unsweetened apple butter is its own recipe, with no sugar in it, separate from the classic.
Batches by lot. Each batch records which ingredient lots it used, so the cider that went into the unsweetened batch is on record.
Recalls. If a batch was made with the wrong cider, one report shows every customer who got it.
| The job | Notebook | In TaroStack |
|---|---|---|
| Which recipe a batch followed | Remembered | Each batch from its recipe |
| Which cider went in | Not recorded | Batches by lot |
| Who got a mislabeled 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.