United States: Concentrates, purées and pastes
Concentrated purées and pastes are not Added Sugars. Concentrated juice can be. Here is the line.
Concentrated purées and pastes are not Added Sugars under FDA rules. Concentrated juice can be. The trigger is the form of the ingredient — whether it is still recognizably the whole fruit — not how concentrated it is.
Which concentrates count as Added Sugars?
FDA draws the line at whether the ingredient still resembles the whole food.
Purées, pastes and some powders retain the basic properties of the whole fruit or vegetable. You removed water; the fruit is still there. Their sugars stay naturally occurring, and they contribute 0g Added Sugars. FDA reasons from the physical form rather than setting a concentration limit, so removing more water does not by itself change the answer.
Juice is different. Pressing fruit into juice discards the structure of the whole food, so FDA applies an excess test: only the sugars beyond what single-strength 100 percent juice of the same type would provide count as Added Sugars.
FDA sets this out in questions 6 and 7 of its Q&A guidance (November 2018, revised December 2019). The distinction is about the form of the ingredient, not the degree of concentration.
The trigger is juice, not concentration. A strawberry purée concentrate contributes 0g Added Sugars however concentrated it is, because it is a purée. An apple juice concentrate is assessed under the excess rule, because it is juice.
Which side is your ingredient on?
| Ingredient | Form | Added Sugars? |
|---|---|---|
| Tomato paste | Concentrated vegetable paste | No |
| Strawberry purée concentrate | Concentrated purée | No |
| Apple purée / sauce | Purée | No |
| Whole-fruit powder | Powder from whole fruit | No |
| Date paste | Paste from whole fruit | No |
| Apple juice concentrate | Juice concentrate | Excess rule applies |
| White grape juice concentrate | Juice concentrate | Excess rule applies |
| Juice powder | Powder made from juice | Excess rule applies |
| Pear juice concentrate used to sweeten | Juice concentrate | Excess rule applies |
A powder made from juice is treated as juice concentrate. The powder form is not what matters; the juice origin is.
What are the four exclusions?
Even where you are dealing with juice concentrate, four cases contribute nothing. These are the complete codified list at 21 CFR 101.9(c)(6)(iii):
- Juice concentrated from 100 percent juice and sold to consumers as such — frozen concentrate on a retail shelf.
- Concentrate counted toward the percent juice declaration under 21 CFR 101.30, or used for Brix standardization under 21 CFR 102.33(g)(2).
- Concentrate forming the fruit component of jellies, jams or preserves under the standards of identity at 21 CFR 150.140 and 21 CFR 150.160.
- The fruit component of fruit spreads.
The third and fourth exclusions are narrow. They cover the fruit component of those specific products — not sugar separately added to them, and not concentrate used to sweeten a product that is merely fruit-flavored.
How do you apply the excess rule?
The test is whether the water in your finished product is enough to bring the concentrate back to single-strength juice. If it is, nothing is in excess.
FDA sets out a method in question 12 of its Q&A guidance. The steps below follow it.
- Find the sugars the juice ingredient contributes. Its Brix reading, applied to the amount used.
- Find the water content of the finished product — after baking or drying, not of the wet mix.
- Express the juice sugars as a proportion of that water.
- Compare against the single-strength Brix for that juice type. The values are published in 21 CFR 101.30; FDA accepts them as an estimate in question 8 of the guidance, not in the regulation itself.
- The excess above single strength is Added Sugars, added to any other added-sugar ingredients in the formulation.
Two things about step 2. All the water in the finished formulation counts, not just water you added for that purpose — including water carried in by other ingredients. And it is the water that is still there: baking and drying concentrate the juice ingredient further, and the declaration is based on the finished product.
FDA's language here is permissive rather than mandatory — it says it "believe[s] it is practical" to use all the formulation moisture, and that you "should" account for water loss. The guidance also states you may use an alternative approach that satisfies the regulation. If you use a different method, document it.
You need not declare slight Brix overage arising from ordinary process variability; current good manufacturing practice accepts it (question 8). If you rely on the 21 CFR 101.30 Brix figures, FDA says you must document that in your records (same question, next page) — see Recordkeeping.
Treat the resulting figures as estimates rather than measurements. Degrees Brix is total soluble solids by mass, not sugars alone — it also captures organic acids, minerals and soluble pectin. The non-sugar share varies by fruit, and is larger in tart fruits carrying more acid, so a Brix reading is not interchangeable with a sugars figure. That is a reason not to carry a Brix-derived figure to more precision than your records can defend.
Worked example: a fruit bar
A bar formulated with 100g of apple juice concentrate at 70 Brix, in a finished product carrying 200g of water. Single-strength apple juice has a minimum Brix of 11.5 under 21 CFR 101.30.
Step 1 — sugars from the juice ingredient. 100g at 70 Brix ≈ 70g of sugars.
Step 2 — water content of the finished product. 200g.
Step 3 — the juice sugars as a proportion of that water. 70 ÷ 200 = 35%.
Step 4 — compare with single strength. 35% is well above 11.5%, so the concentrate is not fully reconstituted and there is an excess.
Step 5 — the excess. Single-strength juice in 200g of water would carry 200 × 11.5% = 23g. So 70 − 23 ≈ 47g of Added Sugars.
The zero threshold
The concentrate contributes nothing once there is enough water to dilute it to single strength. Here that is 70 ÷ 0.115 ≈ 609g of water in the finished product. Above that the excess is zero — it never goes negative.
Worked example: a baked bar
Baked and dried products are the harder case, because the water that would have reconstituted the concentrate leaves in the oven.
A granola bar made with 60g of apple juice concentrate at 70 Brix, baked down to a finished batch carrying 40g of water.
- Sugars from the juice ingredient — 60g at 70 Brix ≈ 42g
- Water in the finished product — 40g
- Proportion — 42 ÷ 40 = 105%, far above 11.5%
- What single strength would carry — 40 × 11.5% = 4.6g
- The excess — 42 − 4.6 ≈ 37.4g of Added Sugars
The same concentrate contributes almost all of its sugars here and none in a formulation carrying 609g of water. Nothing about the ingredient changed — only the water around it. That is why you determine this from the finished product, not from the ingredient in isolation.
Where to go next
- How to determine Added Sugars — the full per-ingredient procedure
- Recordkeeping — documenting a Brix-based determination
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.