# United States: Concentrates, purées and pastes
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? [#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](https://www.fda.gov/media/117402/download#page=9) 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? [#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? [#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)](https://www.ecfr.gov/current/title-21/part-101/section-101.9#p-101.9\(c\)\(6\)\(iii\)):
1. **Juice concentrated from 100 percent juice and sold to consumers as such** — frozen concentrate on a retail shelf.
2. **Concentrate counted toward the percent juice declaration** under [21 CFR 101.30](https://www.ecfr.gov/current/title-21/part-101/section-101.30), or used for **Brix standardization** under [21 CFR 102.33(g)(2)](https://www.ecfr.gov/current/title-21/part-102/section-102.33#p-102.33\(g\)\(2\)).
3. **Concentrate forming the fruit component of jellies, jams or preserves** under the standards of identity at [21 CFR 150.140](https://www.ecfr.gov/current/title-21/part-150/section-150.140) and [21 CFR 150.160](https://www.ecfr.gov/current/title-21/part-150/section-150.160).
4. **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? [#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](https://www.fda.gov/media/117402/download#page=17) of its Q\&A guidance. The steps below follow it.
1. **Find the sugars the juice ingredient contributes.** Its Brix reading, applied to the amount used.
2. **Find the water content of the finished product** — after baking or drying, not of the wet mix.
3. **Express the juice sugars as a proportion of that water.**
4. **Compare against the single-strength Brix** for that juice type. The values are published in [21 CFR 101.30](https://www.ecfr.gov/current/title-21/part-101/section-101.30); FDA accepts them as an estimate in [question 8](https://www.fda.gov/media/117402/download#page=11) of the guidance, not in the regulation itself.
5. **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](https://www.fda.gov/media/117402/download#page=11)). If you rely on the [21 CFR 101.30](https://www.ecfr.gov/current/title-21/part-101/section-101.30) Brix figures, FDA says you **must document** that in your records ([same question, next page](https://www.fda.gov/media/117402/download#page=12)) — see [Recordkeeping](/docs/guide/concepts/added-sugars/fda/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 [#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](https://www.ecfr.gov/current/title-21/part-101/section-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-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 [#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 [#where-to-go-next]
* **[How to determine Added Sugars](/docs/guide/concepts/added-sugars/fda/determining-added-sugars)** — the full per-ingredient procedure
* **[Recordkeeping](/docs/guide/concepts/added-sugars/fda/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.*