Added sugars label requirements: how to calculate the line and get it right

Total sugars vs added sugars

Total Sugars, at 101.9(c)(6)(ii), is "the sum of all free mono- and disaccharides (such as glucose, fructose, lactose, and sucrose)." That includes the lactose in milk and the fructose in a strawberry. It carries no percent Daily Value, because, as FDA puts it, "[n]o Daily Reference Value has been established for Total Sugars because no recommendation has been made for the total amount to eat in a day."

Added Sugars sits indented beneath it and does carry a %DV, against a Daily Value of 50 g.

So added sugars can never exceed total sugars on a compliant panel. FDA says as much: "[t]he added sugars declaration should not exceed the total sugars declaration."

What actually counts as added sugars

The definition, verbatim from 101.9(c)(6)(iii):

Added sugars are either added during the processing of foods, or are packaged as such, and include sugars (free, mono and disaccharides), sugars from syrups and honey, and sugars from concentrated fruit or vegetable juices that are in excess of what would be expected from the same volume of 100 percent fruit or vegetable juice of the same type…

The same paragraph carves out three things that are not added sugars: juice concentrated from 100 percent juices sold to consumers; concentrates used toward the juice percentage declaration under 21 CFR 101.30 or for Brix standardization under 21 CFR 102.33(g)(2); and fruit juice concentrates used for the fruit component of jellies, jams, or preserves under 21 CFR 150.140 and 150.160, or of fruit spreads.

In plain terms: white sugar, brown sugar, cane juice, honey, molasses, agave, maple syrup, corn syrup, HFCS, juice concentrate used as a sweetener, and the sugar inside a compound ingredient like chocolate chips or a fruit filling. The lactose in the milk and the fructose in whole blueberries are not.

Is honey added sugar? The single-ingredient rule

Yes, and this is the counterintuitive part. Under the regulation, honey is a source of added sugars. But section 12516 of the 2018 Farm Bill (Pub. L. 115-334) says the labeling requirements "shall not require that the Nutrition Facts label of any single-ingredient sugar, honey, agave, or syrup, including maple syrup, that is packaged and offered for sale as a single-ingredient food bear the declaration 'Includes Xg Added Sugars.'"

So a jar of pure honey omits the gram amount but still declares the percent Daily Value for added sugars.

The reasoning explains why the rule looks strange. Nobody adds sugar to honey, and printing "Includes 17g Added Sugars" on a single-ingredient jar reads as an accusation that the beekeeper adulterated it. But the honey still spends a consumer's added sugars budget when it goes in their tea. The result keeps the dietary information and drops the misleading sentence.

In FDA's example label for pure honey, a 1 Tbsp (21 g) serving shows Total Carbohydrate 17g, Total Sugars 17g carrying 34%† in the percent Daily Value column, and no "Includes Xg Added Sugars" line at all. The dagger points to a footnote inside the panel: "One serving adds 17g of sugar to your diet and represents 34% of the Daily Value for Added Sugars."

This applies to pure, single-ingredient products only. FDA's guidance uses "pure" and "100%" to separate these from products "that contain additional ingredients such as sweeteners or flavorings." Blend anything in — cinnamon honey, a pancake syrup that is corn syrup plus maple flavor, a "raw sugar blend" — and you are back to grams plus %DV in the normal format. Same for any ordinary multi-ingredient food: granola, BBQ sauce, protein bars.

The same guidance covers certain cranberry products: dried cranberries without added flavorings, and cranberry beverages whose total sugars per serving do not exceed a comparable product with no added sugars (same food category, same form, same usage). Those keep the gram declaration and add a dagger pointing to a statement outside the panel, like FDA's example "Sugars added to improve the palatability of naturally tart cranberries."

Compliance date: FDA exercised enforcement discretion for these products "until July 1, 2021." That date has passed, so covered products should already be labeled this way.

Fruit and vegetable juice concentrates

Juice concentrate counts as added sugar only to the extent it exceeds what the same volume of 100% single-strength juice would have contained. Reconstitute apple juice concentrate back to normal apple juice strength and none of it is added sugar. Reconstitute it stronger, or use it as a sweetener in something that is not juice, and the excess counts.

You need the sugar content of single-strength juice to do the math. FDA's Q&A guidance lets you use the Brix table in 21 CFR 101.30: "You also may choose to use the Brix values provided in 21 CFR 101.30 as an estimate of the sugar content of the single strength juice." Apple is 11.5, orange 11.8, grape 16.0, cranberry 7.5, pineapple 12.8, lemon 4.5. Brix is percent soluble solids by weight, so 11.5 Brix means 11.5 g per 100 g of juice.

Worked example

An apple refresher made by reconstituting apple juice concentrate above single strength. Nothing else in the formula contributes sugar.

1. Analyze total sugars. Lab result: 15 g per 100 g of finished beverage.
2. Find the single-strength baseline. 100 g of 100% apple juice at 11.5 Brix contains 11.5 g of sugars.
3. Subtract. 15 − 11.5 = 3.5 g of added sugars per 100 g.
4. Scale to your serving. Weigh it — do not assume. Say your 240 mL serving weighs 250 g. Total sugars = 15 × 2.5 = 37.5 → declare 38 g. Added sugars = 3.5 × 2.5 = 8.75 → declare 9 g.
5. Percent DV. 9 ÷ 50 = 18%.

Two notes on the method. Slight Brix overages above the minimum, the kind normal processing produces, are not something FDA "would expect… to be included in the declaration of added sugars." And if you use the 101.30 values, "you must document this information in the records regarding the amount of added sugars added to the food during processing," under 21 CFR 101.9(g)(10).

For blends, run the calculation per fruit at that fruit's own Brix value and sum. For a multi-ingredient formula, count all the moisture in the formula toward reconstitution before deciding what is in excess.

Fermentation: when yeast eats your sugar

Bread, yogurt, kombucha, kefir, fermented hot sauce. You add sugar, microorganisms consume some of it, and the finished food has less than you put in. FDA addresses this directly, and you have three routes.

Route 1: declare the amount after fermentation. You may declare a reasonable approximation of what remains. The condition is records: you must "make and keep records of all relevant scientific data and information relied upon by the manufacturer that demonstrates the amount of added sugars in the food after fermentation and a narrative explaining why the data and information are sufficient," specific to your type of food, under 21 CFR 101.9(g)(10)(v)(A).

Route 2: declare what you put in. Declare the added sugars added prior to fermentation and keep records to verify it, per 21 CFR 101.9(g). Simplest and most conservative, and it makes your product look sweeter than it is. Most small fermenters take this route because the recordkeeping is a batch sheet rather than a study.

Route 3: petition FDA. With "no way to determine a reasonable approximation" but reason to believe a significant reduction occurred, you may petition under 21 CFR 10.30 for an alternative means of compliance. Not realistically a small-brand option.

One hard limit across all three: added sugars cannot exceed total sugars. If your pre-fermentation number is higher than the analyzed total sugars in the finished product, declare added sugars at the analyzed figure.

And if your product contains only added-type sugars — a kombucha sweetened solely with cane sugar — the sugars remaining after fermentation "must be declared as both total and added sugars." Both lines carry the same number.

Sweeteners, sugar alcohols, and allulose

Non-nutritive sweeteners (sucralose, aspartame, stevia leaf extract, monk fruit) are not mono- or disaccharides, so they never appear in either sugar line. They appear in the ingredient list.

Sugar alcohols (erythritol, xylitol, maltitol, sorbitol) get their own line at 101.9(c)(6)(iv). Declaration is voluntary, but becomes mandatory when a claim is made on the label or in labeling about sugar alcohol or total sugars, or about added sugars when sugar alcohols are present. FDA also treats both caloric and noncaloric sweeteners, "including sugar alcohols," as sweeteners for the "no claims about sweeteners" condition in 101.9(c)(6)(iii), which matters for the under-1-gram omission below.

Allulose is the one that catches people out. It is a monosaccharide, so it ought to count as a sugar, but under FDA's October 2020 guidance the agency intends to exercise enforcement discretion for excluding it from Total Sugars and Added Sugars. It still counts toward Total Carbohydrate, at 0.4 kcal/g.

If sorting which ingredients count is where you are stuck, that is the part Nutrillius does for you. Recipe in, 21 CFR 101.9-compliant panel out in about a minute, added sugars separated from total sugars automatically. $39 one time, PNG/PDF/SVG, 90 days of edits.

Added sugars label requirements: rounding and the under-1-gram rule

Same increments as total sugars, per 101.9(c)(6)(iii):

The percent Daily Value is expressed to the nearest whole percent.

The omission rule: label declaration of added sugars is "not required for products that contain less than 1 gram of added sugars in a serving if no claims are made about sweeteners, sugars, added sugars, or sugar alcohol content." If you take that route and drop the line, the statement "Not a significant source of added sugars" goes at the bottom of the nutrient table. Make any sweetener claim and you lose the option.