United States: Added Sugars under FDA rules
The FDA definition, the four exclusions, label format, rounding, and percent Daily Value.
Added Sugars became a mandatory US declaration in the 2016 Nutrition Facts final rule. The definition, the label format, the rounding bands and the recordkeeping trigger all live in a single dense subparagraph of 21 CFR 101.9. This page unpacks it.
What FDA counts as Added Sugars
Added Sugars are sugars added to the food during processing, or sugar packaged and sold as sugar. Three things count:
- Plain sugars — free mono- and disaccharides, in any form
- Sugars from syrups and honey
- Juice concentrate above single strength — only the amount beyond what ordinary ready-to-drink juice of that type would have provided
Four narrow cases are then carved back out, all of them juice concentrates. They are set out in What the definition excludes below.
The operative text:
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…
One consequence is easy to miss: only the sugar portion of an ingredient counts, not the ingredient itself. A syrup that is 76% sugars contributes 76% of its weight.
What the definition excludes
The same sentence carves out four cases. All four are juice concentrates, and all four contribute 0g.
| What the regulation excludes | What that means in practice |
|---|---|
| "fruit or vegetable juice concentrated from 100 percent juices sold to consumers" | A can of frozen orange juice concentrate on a supermarket shelf. |
| "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)" | Apple concentrate counted so a blend can say "100% juice"; grape concentrate added to bring a weak pressing back up to single strength. |
| "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" | The grape concentrate inside a jar of grape jelly made to that standard. |
| "the fruit component of fruit spreads" | The fruit in a "fruit spread" — a product with no standard of identity. |
The last two are narrower than they sound: they cover the fruit component only, not sugar added alongside it, and not concentrate used to sweeten something merely fruit-flavored. Concentrates, purées and pastes gives the citations and the arithmetic.
Note what is absent. The list does not name non-nutritive sweeteners; they fall outside the definition because they are not free mono- or disaccharides. Sugar alcohols have their own declaration under 21 CFR 101.9(c)(6)(iv).
What do "single strength" and "Brix" mean?
Single strength is juice at the concentration you get from pressing the fruit — ready to drink, neither concentrated nor watered down. It is the baseline the excess rule measures against. Concentrate is the same juice with water removed, so it has to be diluted back to single strength to be drinkable.
Brix is how that concentration is measured: dissolved solids as a percentage by weight, so 12 Brix means 12g of dissolved solids per 100g. In fruit juice most of those solids are sugar, which is why Brix stands in for strength.
Fruit varies with season, weather and ripeness, so a pressing can come out weaker than usual for its type. FDA publishes a minimum Brix for each juice in 21 CFR 101.30 — apple is 11.5, meaning single-strength apple juice should read at least 11.5 Brix. Bringing a weak batch up to that figure with concentrate is standardizing it, and contributes no Added Sugars. Take it above that figure and the excess does count.
What does not count as Added Sugars
Several categories sit outside the definition.
| Ingredient | Added Sugars? |
|---|---|
| Whole fruit, vegetables, grains | No — naturally occurring |
| Unsweetened dried fruit | No — FDA calls it "essentially a dehydrated whole fruit" |
| Concentrated purées and pastes | No — they keep the basic properties of the whole fruit or vegetable. See Concentrates, purées and pastes. |
| Milk, milk powder, whey (inherent lactose) | No |
| Purified lactose — the 21 CFR 168.122 standard of identity | Yes — same molecule, opposite answer. Decided in Q&A guidance question 16; the CFR section only defines what lactose is. |
| Allulose | Excluded from Total and Added Sugars under FDA enforcement discretion — not by the regulation. Still counted in Total Carbohydrate. See below. |
| Sugar alcohols | No — separate declaration under (c)(6)(iv). See below. |
| Stevia, sucralose, monk fruit | No — not sugars |
Is allulose an Added Sugar?
Under the regulation as written, yes. Allulose is a monosaccharide, and FDA's October 2020 final guidance states it "must be included" in Total Carbohydrate, Total Sugars and Added Sugars, and restates it for Added Sugars specifically as applying "pending any future rulemaking."
FDA then says it intends to exercise enforcement discretion for excluding allulose from Total Sugars and Added Sugars, and for a caloric value of 0.4 kcal/g. That discretion does not extend to Total Carbohydrate, where allulose must still be counted.
The practical answer is that you may leave it out of both sugar lines. The distinction matters because this is a stated FDA position rather than a codified exclusion, and it is expressly provisional.
Are sugar alcohols Added Sugars?
No. Sugar alcohols — erythritol, xylitol, maltitol, sorbitol — are not free mono- or disaccharides, so they sit outside the definition. They are excluded from Total Sugars as well, and carry their own voluntary declaration under 21 CFR 101.9(c)(6)(iv).
Maltitol syrup is a syrup, it sweetens, and the Added Sugars definition names syrups. It contributes nothing, because it is not a sugar.
Sugar alcohols do matter in one direction. A claim about sugar alcohols counts as a sweetener claim, and that removes the under-1g omission exemption for Added Sugars described below.
How the declaration appears on the label
Added Sugars is indented directly beneath Total Sugars and prefaced with the word "Includes":
Total Sugars 12g
Includes 8g Added Sugars 16%The word "Includes" signals that the 8g is part of the 12g above it, not additional to it.
One product type is exempt from that wording: a single-ingredient sugar, honey, agave or syrup may omit the "Includes Xg" phrase while still showing the percent Daily Value, under a 2018 statute the regulation was never updated to reflect. See Single-ingredient sugars and syrups.
For everything else the regulation requires that exact construction — "Includes 'X' g Added Sugars" — and 21 CFR 101.9(d)(1)(v) calls for a hairline rule between nutrient rows. The shortened hairline that visually marks Added Sugars as a subset of Total Sugars comes from the graphic specifications in Appendix B to Part 101, not from the rule text.
Added Sugars carries a percent Daily Value; Total Sugars does not. That asymmetry is deliberate — FDA set a Daily Reference Value for Added Sugars but not for total sugar intake.
How do you round Added Sugars?
Three bands, and only three:
| Amount per serving | Declaration |
|---|---|
| Less than 0.5g | May be expressed as 0g, or as "less than 1 gram" |
| 0.5g to less than 1g | Rounds to the nearest gram, or may state "less than 1 gram" |
| 1g and above | Round to the nearest gram |
Added Sugars has no 0.5-gram rounding step. Trans fat does — it rounds to the nearest 0.5g between 0.5 and 5g under 21 CFR 101.9(c)(2)(ii) — and the two lines sit close together on the panel.
The percent Daily Value is expressed to the nearest whole percent. Under 21 CFR 101.9(d)(7)(ii) you may calculate it from either the declared (rounded) amount or the actual amount before rounding — both are lawful, and you should pick one and apply it consistently.
What is the percent Daily Value based on?
The Daily Reference Value for Added Sugars comes from the table at 21 CFR 101.9(c)(9):
| Population | DRV |
|---|---|
| Adults and children 4 years and older | 50g |
| Children 1 through 3 years | 25g |
| Pregnant and lactating women | 50g |
| Infants through 12 months | None established |
The 50g figure is based on a 2,000-calorie reference intake; the 25g figure on 1,000 calories. Labels for infants through 12 months carry no percent Daily Value for Added Sugars at all, under 21 CFR 101.9(j)(5)(ii)(A).
Pick the Daily Value that matches the population your product is labeled for, not the one you see most often. FDA Daily Values carries the same figures for every nutrient, so you can check Added Sugars against the rest of the panel in one place.
When the declaration may be omitted
Added Sugars may be left off only when both conditions hold: the serving contains less than 1g, and you make no claims about sweeteners, sugars, Added Sugars, or sugar alcohol content. Both conditions are in 21 CFR 101.9(c)(6)(iii).
If you omit it on that basis, the same paragraph requires "Not a significant source of added sugars" at the bottom of the nutrient table, in the same type size.
Note the breadth of the claim condition. A "no sugar added" flag on the front of the package, or any sweetener claim, removes the exemption and the declaration becomes mandatory again. FDA's guidance also treats sugar alcohols as sweeteners for the purpose of this trigger, so a sugar-alcohol claim has the same effect.
How FDA verifies a declaration it cannot measure
FDA states the underlying problem directly in the preamble to the 2016 final rule:
Because added sugars and naturally occurring sugars are not chemically distinct, it is not possible to do a laboratory analysis to determine the amount of added sugars in a product that contains both naturally occurring sugars and added sugars.
That constraint is why the compliance mechanism for this nutrient is different from every other one on the panel.
Calories, sugars, fats, cholesterol and sodium are policed by laboratory analysis against a tolerance: a food is misbranded if the composite contains more than 20 percent in excess of the declared value, under 21 CFR 101.9(g)(5). (Vitamins, minerals, protein and fiber sit under 21 CFR 101.9(g)(4) instead, which sets a floor rather than a ceiling.) Read that provision carefully and you will find Added Sugars carries a parenthetical:
…added sugars (when the only source of sugars in the food is added sugars)…
When your food contains both added and naturally occurring sugars — which is almost every formulated food — the analytical route does not apply. FDA verifies the declaration through your records instead, under 21 CFR 101.9(g)(10) and (11).
Records are therefore the verification mechanism for this declaration, and 21 CFR 101.9(g)(11) requires them to be produced on request. See Recordkeeping for Added Sugars.
Where to go next
- How to determine Added Sugars for a recipe — the per-ingredient decision procedure
- Concentrates, purées and pastes — which concentrated forms contribute, and which do not
- Single-ingredient sugars and syrups — honey, maple syrup, and the dagger footnote
- Fermentation and browning — when sugar is consumed during processing
- Recordkeeping — what to keep, in what form, for how long
This page is educational and is not legal advice. FDA guidance documents cited here state FDA's current thinking and are not binding — you may use an alternative approach that satisfies the regulation. Verify every rule against the current regulation and your own regulatory counsel before relying on it for a commercial label.