Added Sugars Labeling Requirements: FDA Rules
Added sugars labeling requirements explained, including what counts as added sugar, the Includes line, rounding, exemptions and FDA records.
The added sugars labeling requirements in 21 CFR 101.9(c)(6)(iii) define what counts as added sugar, identify four exclusions, prescribe how added sugars appear on the Nutrition Facts label, and create recordkeeping duties for many foods containing sugar. The related records provisions are in 101.9(g)(10) and (g)(11).
Every requirement below comes from the current text of 21 CFR 101.9, starting with the definition because whether a sugar belongs on the added sugars line depends first on why and how it entered the food.
What FDA added sugars labeling requirements count as added sugar
The definition is one sentence with three inclusion limbs and four exclusions, quoted closely 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, except that fruit or vegetable juice concentrated from 100 percent juices sold to consumers, fruit or vegetable juice concentrates used towards the total juice percentage label declaration under 101.30 or for Brix standardization under 102.33(g)(2) of this chapter, fruit juice concentrates which are used to formulate the fruit component of jellies, jams, or preserves in accordance with the standard of identities set forth in 150.140 and 150.160 of this chapter, or the fruit component of fruit spreads shall not be labeled as added sugars."
Read the opening clause carefully. "Either added during the processing of foods, or are packaged as such" creates a two-part test.
The first part is straightforward: you put sugar into the formula. The second covers products where nothing was added to another food because the sugar itself is the product. A bag of table sugar, a bottle of agave or a jar of syrup has no processing step in which sugar was added to it, but it is packaged as sugar, so its entire sugar content is added sugars.
The three inclusion limbs identify which forms qualify.
First are sugars, meaning free mono and disaccharides, including sucrose, glucose, fructose, dextrose and maltose in any commercial form.
Second are sugars from syrups and honey, including corn syrup, high fructose corn syrup, malt syrup, rice syrup, molasses, maple syrup and honey. The regulation explicitly names honey, so being a natural sweetener does not put it outside the definition.
Third are sugars from concentrated fruit or vegetable juices, but only to the extent that they exceed what the same volume of 100 percent juice of the same type would contribute. A concentrate reconstituted to single strength contributes nothing to the added sugars line. The same concentrate used undiluted as a sweetener contributes the difference. The words "of the same type" matter: apple juice concentrate is compared with apple juice, not a generic juice figure.
The four exclusions all concern juice concentrates. None excludes cane sugar, honey or syrups:
- Fruit or vegetable juice concentrated from 100 percent juices sold to consumers, such as frozen concentrate a shopper reconstitutes at home.
- Juice concentrates used towards the total juice percentage declaration under 21 CFR 101.30.
- Juice concentrates used for Brix standardization under 21 CFR 102.33(g)(2), bringing juice back to its standard sugar level rather than sweetening it.
- Fruit juice concentrates used for the fruit component of jellies, jams or preserves under the standards of identity in 21 CFR 150.140 and 150.160, and the fruit component of fruit spreads.
Two other categories sit outside the definition. Sugar alcohols are not sugars and have their own voluntary line under 101.9(c)(6)(iv). Naturally occurring sugars that were never added and never packaged as sugar are also outside it, such as lactose in milk or fructose in a diced peach.
Added sugars labeling: the mandatory declaration and placement
The regulation specifies the form of words. Added sugars content "shall be indented under Total Sugars and shall be prefaced with the word Includes followed by the amount (in grams) Added Sugars".
The line therefore reads: the word Includes, the number, a space and the letter g, followed by the words Added Sugars. It is not "Added Sugars 9g" or "of which added sugars."
The declaration is mandatory for every food bearing a Nutrition Facts label that contains 1 g or more of added sugars per serving. Placement and typography come from 101.9(d), and those requirements produce a line that looks different from the Total Sugars line above it:
| Requirement | What it means on the panel | Source |
|---|---|---|
| Indented under Total Sugars | Below Total Sugars and inset from it, inside the carbohydrate block | 101.9(c)(6)(iii) |
| Name not highlighted | Only non-indented nutrient names are bold, so the Includes text is regular weight | 101.9(d)(1)(iv) |
| Percentage highlighted | Every percent Daily Value is bold, so the percentage is bold beside non-bold text | 101.9(d)(1)(iv) |
| Type size floor | No smaller than 8 point | 101.9(d)(1)(iii) |
| Abbreviation | Includes may be shortened to Incl., including on the dual column displays | 101.9(j)(13)(ii)(B) |
The percentage in the bold column comes from the Daily Value table in 101.9(c)(9):
- 50 g for adults and children 4 years and older and for pregnant and lactating women.
- 25 g for children 1 through 3.
- No Daily Value for infants through 12 months.
Under 101.9(j)(5)(ii)(A), labels for infants through 12 months show no percent Daily Value for added sugars at all and carry no footnote.
Labels for children 1 through 3 do carry a percent Daily Value against the 25 g Daily Value, and 101.9(j)(5)(iii) requires a footnote stating that 1,000 calories a day is used for general nutrition advice.
Take the sauce in the figure. At 9 g added sugars per serving, dividing by the 50 g Daily Value gives 18 percent, so the line reads Includes 9 g Added Sugars with 18% beside it.
On a label for children 1 through 3, the divisor is 25 g and the same 9 g becomes 36 percent. The grams do not change. The percentage doubles.
Added sugar label requirements for rounding
Added sugars use the plain gram ladder, the same one used for total sugars, dietary fiber and protein. There are three rungs and no others.
| Analytical amount per serving | What you may declare | Worked example |
|---|---|---|
| 1 g or more | Expressed to the nearest gram | 8.6 g declares as 9 g |
| 0.5 g up to but not including 1 g | "Contains less than 1 gram" or "less than 1 gram" | 0.7 g declares as less than 1 g |
| Less than 0.5 g | May be expressed as zero | 0.3 g declares as 0 g |
Three details commonly cause errors.
First, the symbol "<" may replace "less than" under 101.9(d)(7)(i), so "Incl. <1 g Added Sugars" is compliant on a panel short of room.
Second, the sub-0.5 g rule is permissive. The content "may be expressed as zero", so declaring 0 g is a choice. Omitting the line is the separate alternative covered below.
Third, these rounding rules govern only the gram amount. The percentage has its own rule in 101.9(d)(7)(ii): round to the nearest whole percent using either the amount declared on the label or the actual amount before rounding.
Both inputs are permitted. Two compliant labels for the same sauce can therefore differ by a percentage point. Pick one method and apply it consistently. The nutrient-specific ladders are set out in FDA rounding rules explained.
One additional constraint comes not from the rounding rules but from 101.9(g)(10)(v)(B): in no event shall the amount of added sugars declared exceed the amount of total sugars on the label.
If the indented added sugars line is larger than Total Sugars above it, the panel is wrong on its face.
When added sugars may be omitted, and the statement required instead
An added sugars declaration is not required for a product containing less than 1 gram of added sugars per serving, but only "if no claims are made about sweeteners, sugars, added sugars, or sugar alcohol content".
Both conditions must be satisfied. If you make any claim in that family, you must declare the line even when the food contains only 0.2 g of added sugars. The claim validator lists which sugar and sweetener claims are defined, so you can check whether wording on the front panel has pulled the declaration back in.
If the declaration is not required and you choose not to declare it, the Nutrition Facts panel cannot simply stay silent. The statement "Not a significant source of added sugars" shall appear at the bottom of the table of nutrient values in the same type size.
The wording is prescribed. A paraphrase such as "contains no added sugars" does not satisfy the obligation and is, in any case, a claim that reinstates the declaration. The required statement must use the same type size as the table, rather than being reduced to fit.
One carve-out is signaled by the opening words "Except as provided for in paragraph (f) of this section". This refers to the simplified format, available when a food contains insignificant amounts of eight or more of the fifteen listed nutrients, or six or more of twelve for foods intended for infants through 12 months and children 1 through 3.
In the simplified format, the statement takes the consolidated form under 101.9(f)(4), naming every nutrient present in insignificant amounts in one line.
A food containing 0.3 g of added sugars per serving and making no sugar claims therefore has three compliant treatments:
- Declare Includes 0 g Added Sugars with 0% Daily Value.
- Omit the line and place "Not a significant source of added sugars" at the bottom of the table of nutrient values.
- Use the simplified format if the food qualifies.
Panel space can decide which treatment you use.
FDA added sugars recordkeeping requirements
Added sugars carry an explicit recordkeeping duty for an analytical reason. A laboratory measuring sugars in a finished yogurt cannot distinguish fructose that arrived in fruit from fructose that arrived in cane sugar. The declared added sugars value is therefore a formulation figure rather than simply a measurement, and the regulation requires you to support the formulation.
The trigger appears at the end of 101.9(c)(6)(iii). When a mixture of naturally occurring and added sugars is present, and for foods where added sugars are subject to fermentation or non-enzymatic browning, the manufacturer must make and keep records under 101.9(g)(10) and (11).
The second trigger is broad. Non-enzymatic browning is the Maillard reaction, so bread, baked goods, roasted products and anything with a browning step are in scope. Fermentation brings in yogurt, sourdough, vinegar-based products and fermented beverages.
Paragraph (g)(10) identifies the evidence FDA has in mind: "analyses of databases, recipes, formulations, information from recipes or formulations, or batch records".
For the ordinary case, 101.9(g)(10)(iv) requires written records of the added sugars put into the food during processing and, if packaged as a separate ingredient, as packaged. In practice, this is the formulation file, and it is what an investigator asks for first.
Where non-enzymatic browning or fermentation reduces the amount of sugars, 101.9(g)(10)(v) provides three routes. You must use one.
- Route A. Keep all relevant scientific data demonstrating the added sugars remaining after browning or fermentation, plus a narrative explaining why the evidence is sufficient. The evidence must be specific to the type of food subject to the reaction, so a general paper on Maillard losses in baked goods will not support a figure for your sourdough.
- Route B. Keep records of the amount added before and during processing, and as packaged if packaged as a separate ingredient, then declare on that basis. This approach ignores the losses. You declare the sugar you put in, subject to the rule that declared added sugars may not exceed total sugars.
- Route C. Petition under 21 CFR 10.30 for an alternative means of compliance, showing why the reduction is likely to be significant, meaning large enough to affect the declaration by more than the reasonable deficiency allowed under 101.9(g)(6), and why you cannot determine a reasonable approximation.
Route B is the pragmatic default for bakers and fermenters. It produces a slightly conservative number without requiring you to prove the loss.
Paragraph (g)(11) sets the terms of custody, and this is where records can fail an inspection even when they exist.
Records must be kept for at least 2 years after introduction or delivery for introduction of the food into interstate commerce. They must be provided to FDA on request during an inspection for review and copying.
They may be originals, true copies such as photocopies, scans or microfilm, or electronic records kept under 21 CFR part 11. They must also be "accurate, indelible, and legible".
Failure to keep or produce the required records would result in the food being misbranded under section 403(a)(1) of the act. The number printed on the label can be correct and the product still misbranded because the supporting file is not there.
Single-ingredient sugars and syrups under FDA added sugars rules
Pure honey, pure maple syrup, table sugar and other single-ingredient sugars and syrups sit awkwardly inside the definition.
They have no naturally occurring sugars to distinguish from added sugars and are "packaged as such". On a literal reading, the Includes line would simply repeat the Total Sugars figure.
FDA addressed this in final guidance issued 18 June 2019, "The Declaration of Added Sugars on Honey, Maple Syrup, Other Single-Ingredient Sugars and Syrups, and Certain Cranberry Products": these products need not declare the gram amount on the Includes line, but must still declare the percent Daily Value.
That is guidance. It is nonbinding and is not codified in 101.9. The regulation quoted above is what binds.
The dagger symbol, footnote wording and cranberry products provision are worked through in added sugars on the Nutrition Facts label.
Once you have made the ingredient-by-ingredient determination, the rest is mechanical. The nutrition label generator will sum the qualifying sugars, apply the gram ladder, divide by the correct Daily Value for your age group, and set the indented Includes line in the standard, dual column and small package formats.
Frequently asked questions about added sugars labeling requirements
Is fruit juice concentrate in my recipe an added sugar?
It depends on how much you used. Under 101.9(c)(6)(iii), added sugars are those in excess of what the same volume of 100 percent juice of the same type would contribute. Reconstitute the concentrate to single strength and the excess is zero. Use it undiluted as a sweetener and the excess is most of it.
Do I have to declare added sugars if my product has 0.4 g per serving?
No, provided you make no claims about sweeteners, sugars, added sugars or sugar alcohol content. You can declare 0 g because amounts below 0.5 g may be expressed as zero, or omit the line and use "Not a significant source of added sugars" at the bottom of the nutrient table. A sugar or sweetener claim removes the exemption.
Can the added sugars figure be larger than total sugars?
No. Under 101.9(g)(10)(v)(B), the amount of added sugars declared cannot exceed total sugars on the label. A common cause is fermentation or browning that consumed sugar you are still counting, or calculating added sugars from ingredient inputs while obtaining total sugars from analysis of the finished product.
How long do I have to keep added sugars records?
At least 2 years after introduction or delivery for introduction of the food into interstate commerce, under 101.9(g)(11). You must produce the records to FDA on request during an inspection. They may be originals, true copies or part 11 compliant electronic records, and must be accurate, indelible and legible.
Does the Includes Added Sugars line have to be bold?
No. The words are not bold, but the percentage is. Under 101.9(d)(1)(iv), only nutrient names that are not indented receive bold or extra bold highlighting, and added sugars is indented. The same paragraph requires every percent Daily Value to be highlighted, while 101.9(d)(1)(iii) requires the entire line to be at least 8 point.
