Regulatory Update: The Complexities of Labeling Added Sugar

Regulatory Update: The Complexities of Labeling Added Sugar

January 18, 2017
Annette Maggi
RegulatoryRetail Industry Insights

By RDBA Executive Director Annette Maggi, MS, RD, LD, FAND

While opinions vary on the value of including added sugar in the new Nutrition Facts Panel (NFP), there are a variety of complexities in actually getting the information onto the label. Today’s article reviews these complexities.

  • “Sugar” in an ingredient declaration is different that “added sugar” in the NFP. Some manufacturers in the natural foods industry incorrectly assumed that ingredients like date and coconut sugar wouldn’t have to be declared as added sugar on the new NFP because they don’t meet the definition of sugar for ingredient declarations. For nutrition purposes, the chemical definition of mono- and disaccharides is used to determine what must be listed. Ingredients like date and coconut sugar meet this definition, and must be listed as “added sugar.”  
  • Analytical testing cannot differentiate between naturally-occurring and added sugar. Often, food manufacturers and ingredient suppliers rely on analytical testing to determine or verify levels of nutrients in an ingredient or finished product. With sugar, this simply isn’t an option. This creates many challenges in providing accurate information on added sugars, especially as it relates to sub-ingredients and fermented foods. Take, for example, yogurt-covered raisins used in a packaged trail mix. The supplier must determine the amount of sugar in the yogurt coating that is inherent vs. added, which is complex given the fact that some of the moisture is taken out of the product and all sugars are concentrated. Then consider that sugar is fermented in yogurt, and the ingredient supplier must now try to determine how much natural sugar vs. added sugar is fermented in the process of making yogurt. The reality is that these complexities add cost all along the food supply chain, which may eventually be passed on to the consumer. With heating or prolonged storage of juices and other ingredients, the sugar in these foods can be degraded in a non-enzymatic browning process. This effect must also be accounted for in labeling, which becomes complex if there are natural and added sugars in the product.  
  • Concentrated fruit and vegetable juices count as added sugar. Juices are often concentrated and used as an ingredient in foods. Take, for example, an orange or lemon chicken frozen entrée, which may use a concentrated form of the juice in the chicken sauce. The sugar in this juice would be considered “added sugar” if the juice is more concentrated than 100% fruit juice. FDA adds clarity to how other concentrated forms of fruits and vegetables should be handled as it relates to added sugar labeling, “If the ingredient contains all of the components of a whole fruit or vegetable, but has been processed so that the plant material is physically broken down into smaller pieces or water is removed, we would not consider the sugars contributed from the portion of the fruit or vegetable that is typically eaten which is used to make such an ingredient to be added sugars.”

In light of the multitude of questions being asked about the details of labeling added sugars, earlier this month the Food and Drug Administration published clarifying guidance.  It is available here