The Health Trend in the US Market: Regulation Takes the Lead
In recent years, American consumers have become increasingly concerned about their sugar intake in food, particularly regarding "hidden sugars" and "added sugars." Against this backdrop, the US Food and Drug Administration (FDA) officially mandated the separate labeling of "Added Sugars" on food packaging, marking a profound reform in food labeling history.
Starting in 2020, the FDA significantly updated the Nutrition Facts Label, with "Added Sugars" now one of the nutrients that must be listed separately. During our US export process, MiniCrush proactively responded to the regulations, optimizing labels and formulas to help clients address this labeling compliance challenge.
I. "Total Sugars" vs. "Added Sugars": What are the differences in legal definitions?
According to official FDA documents:
Total Sugars refers to the total amount of all naturally occurring and artificially added monosaccharides and disaccharides in a product, including lactose, fructose, glucose, and others.
Added Sugars: These are sugars added during food processing, such as cane sugar, corn syrup, honey, and fruit juice concentrate. They do not
include sugars found naturally in fruit or milk.
This means that even if a product is flavored with fruit juice concentrate, syrup, or honey instead of using cane sugar directly, it must be included in the "added sugars" list.
II. FDA Mandatory Labeling Requirements: Grams + % Daily Value (DV)
On the new label, added sugars must include two indicators:
"Grams" (g): This indicates the specific amount of added sugars per serving.
"% Daily Value" (DV): This is calculated based on a 50-gram daily reference value (i.e., the recommended daily intake of added sugars is no more
than 50 grams), helping consumers assess the product's contribution to their daily diet.
Example:
Added Sugars 12g
24% Daily Value
This means that each serving of this product contains 12 grams of added sugars, which contributes to 24% of the recommended daily value.
3. "Sugar-Free," "Low Sugar," and "No Added Sugar": Labeling Terms Also Have Strict Standards
When enforcing labeling compliance, not only must "added sugar" be correctly labeled, but any terms that imply "reduced sugar" or "health-oriented" must also comply with FDA regulations:
| Term | Definition | Scope |
| Sugar-Free | Sugar content ≤ 0.5g per serving. | Applicable to sugar substitute products, such as sweetened beverages and sugar-free gummies. |
| Low Sugar | No FDA definition, generally refers to a significantly lower sugar content than similar products. | Caution is advised as this may be subject to interpretation disputes. |
| No Added Suga | No added sugar or sugar-containing ingredients (such as honey or juice concentrate) are used during processing. | The label "Contains natural sugars" or "Not a low-sugar food" must also be stated. |
MiniCrush strictly adheres to the "sugar-free" standard of ≤ 0.5g of sugar per serving when exporting products to the United States. For example, gummies and jellies use natural sweeteners such as erythritol and stevia instead of sucrose to avoid regulatory violations.
Potential Consequences of Label Noncompliance
Label noncompliance not only means product returns and rectifications, but in serious cases, the product may be placed on the FDA's "Violation Notification List," potentially leading to product removal from shelves or import bans. MiniCrush recommends the following compliance measures:
- Regularly verify nutrient content laboratory test values;
- Review English labeling to ensure it matches FDA terminology;
- Clarify "serving size" and sugar/sugar substitute sources;
- Adapt sugar substitute formulas to regulatory requirements. For example, while allulose is compliant in the US, it remains restricted in the EU.
MiniCrush has provided collaborative label review services to multiple North American clients, helping them successfully pass FDA import inspections.