United States: How to determine Added Sugars
A per-ingredient decision procedure for determining Added Sugars from a formulation.
FDA publishes no mandatory formula for Added Sugars and no calculator. The determination is yours to make from your formulation, and yours to substantiate. This page gives an ordered procedure you can work by hand, in a spreadsheet, or in any tool you already use.
The equation everything serves
Recipe Added Sugars = Σ ( ingredient grams × added sugars per 100g ÷ 100 )The entire procedure below exists to fill in one value per ingredient: added sugars per 100g.
That value is a fraction of the ingredient's sugars, not of the ingredient. 60g of honey does not contribute 60g of Added Sugars. Honey is 82.1g sugars per 100g, so it contributes 49.26g. FDA is explicit that "only the sugar portion of the ingredient should be declared" (81 FR 33742 at 33838).
Can you calculate Added Sugars from Total Sugars?
No. There is no subtraction that gets you from one to the other.
Total Sugars is measured. Added Sugars is derived from your formulation. Because no analysis distinguishes a sugar molecule that came from cane sugar from one that came from a banana, nothing in the finished product tells you how to split the total.
Total Sugars does one job here: it sets the ceiling. Added Sugars can never exceed Total Sugars. Check that on every formulation.
How to read the procedure
Start at Q1 and work down. Stop at the first question that resolves your ingredient — each one tells you what it produces, and several will redirect you if the answer belongs elsewhere.
If your product ferments or browns, read step R1 before you start. Bread, kombucha, yogurt, beer and caramelized products have three legally distinct routes, and the one you choose changes what you need to record — and can make per-ingredient precision unnecessary.
Three outcomes, and the third is as legitimate as the other two. Each question below says which one it produces.
Q1 — Does the ingredient contain any sugars?
If an ingredient contains no sugars, it contributes no Added Sugars. Salt, oil, water, leavening agents and most spices resolve here immediately.
This question exists to clear the majority of a typical ingredient list before you spend judgment on the rest.
Q2 — Is it a sweetener that is not a sugar?
Several ingredients are sold as sweeteners, are used as sweeteners, and are not Added Sugars. Check for these before Q3, because Q3 would otherwise capture them by name.
| Ingredient | Treatment |
|---|---|
| Sugar alcohols — erythritol, xylitol, maltitol, sorbitol, and syrups made from them | Not mono- or disaccharides, so outside the definition. Separate voluntary declaration under 21 CFR 101.9(c)(6)(iv). Also excluded from Total Sugars. |
| Allulose | Excluded from Total Sugars and Added Sugars; still counted in Total Carbohydrate, at 0.4 kcal/g (FDA guidance, final October 2020). |
| Non-nutritive sweeteners — stevia, sucralose, aspartame, monk fruit | Not sugars at all. Nothing to declare in either line. |
Maltitol syrup resolves here. It is a syrup, it sweetens, and Q3 names syrups — but it is a sugar alcohol, so it contributes 0g Added Sugars.
These ingredients still matter elsewhere. A claim about sugar alcohols counts as a sweetener claim, which removes the under-1g omission exemption for Added Sugars.
Q3 — Is it a caloric sweetener or a syrup?
Table sugar, brown sugar, powdered sugar, turbinado, high-fructose corn syrup, corn syrup, glucose, dextrose, fructose, invert sugar, honey, maple syrup, agave, molasses, malt syrup, sorghum and brown rice syrup all resolve here.
All of their sugars are Added Sugars. The regulation names the category directly: "sugars from syrups and honey" (21 CFR 101.9(c)(6)(iii)).
This holds even when the ingredient's own package declares 0g Added Sugars. Single-ingredient honey, maple syrup and sugar packers may legally omit that line under the 2018 Farm Bill. The zero on the jar describes how that jar is labeled — it does not describe what the honey contributes to your formulation.
Take the sugar portion, not the ingredient weight. Honey at 82.1g sugars per 100g: 60g of honey contributes 60 × 82.1 ÷ 100 = 49.26g.
What "its sugars" means on a specification sheet
Use the ingredient's Sugars figure — its free mono- and disaccharide content. That is the number a Nutrition Facts panel or a supplier specification reports as "Sugars", and it is the same quantity Q4 calls the mono- and disaccharide portion. The two questions are not in conflict; they name the same measurement for different reasons.
Do not use total carbohydrate. The two figures diverge for syrups carrying longer-chain carbohydrates, and brown rice syrup shows the gap clearly: it is a mixture of glucose, maltose, maltotriose and longer glucose chains, and only the first two are mono- or disaccharides.
To illustrate with round numbers — a specification showing 79g total carbohydrate and 29g sugars per 100g contributes 29g, not 79g. The maltotriose and longer chains making up the balance fall outside the definition. Use your own supplier's figures rather than these; the point is which column to read, not the values.
Q4 — Is it a controlled-hydrolysis product?
Maltodextrin, corn syrup solids, malt extract, and the enzymatic hydrolysis used to produce oat and rice beverages all create free mono- and disaccharides from starch. That portion is Added Sugars.
FDA addresses this in questions 14 and 15 of its Q&A guidance (November 2018, revised December 2019). Two points matter. First, the purpose need not be sweetening — hydrolyzing starch to build body or viscosity still counts. Second, the rule applies to controlled hydrolysis carried out as a processing step; sugars arising incidentally are not captured.
Q5 — Is it purified lactose?
Lactose meeting the standard of identity at 21 CFR 168.122 contributes Added Sugars. Lactose inherent in milk, milk powder, cream or whey does not.
The same molecule, the opposite answer, decided entirely by how it arrived in your formulation. FDA sets this out in question 16 of the Q&A guidance, which also confirms that hydrolyzing lactose with lactase changes neither Total Sugars nor Added Sugars — it splits a disaccharide into two monosaccharides without changing where they came from.
Q6 — Is it a whole or minimally processed food?
Fruit, vegetables, grains, meat, nuts, milk, plain yogurt and unsweetened dried fruit contribute 0g Added Sugars.
So do concentrated purées, pastes and some powders. FDA's reasoning in questions 6 and 7 of the Q&A guidance is that these "maintain the basic properties of a whole fruit or vegetable" — the whole food is still there, just with water removed.
Read the ingredient statement, not the name. This question clears single-ingredient foods only. If the ingredient is itself made from more than one ingredient, it belongs at Q8 however wholesome its name sounds. A peanut butter may declare only peanuts and salt, or it may declare peanuts, sugar, salt and oil — the name is the same either way, and only the ingredient statement tells you which you have. Granola, nut butters, chocolate and yogurt bases all vary the same way.
A name may announce added sugar — sweetened, candied, glazed, in heavy syrup, honey-roasted — but it does not have to. Treat the name as a prompt to check, never as the answer.
A powder made from juice is treated as juice concentrate — go to Q7.
The purée exemption has its own page: Concentrates, purées and pastes.
Q7 — Is it a fruit or vegetable juice concentrate?
Only the sugars in excess of what single-strength 100 percent juice of the same type would provide are Added Sugars. Single strength is the concentration you get from pressing the fruit — ready to drink, neither concentrated nor watered down. Concentrate used simply to dilute back to that point adds nothing.
Four cases contribute 0g regardless of concentration:
- Juice concentrated from 100 percent juice and sold to consumers as such
- Concentrate counted toward the percent juice declaration (21 CFR 101.30) or Brix standardization (21 CFR 102.33(g)(2))
- Concentrate forming the fruit component of jams, jellies or preserves (21 CFR 150.140 and 21 CFR 150.160)
- The fruit component of fruit spreads
The comparison is made on Brix. FDA accepts the minimum Brix values published in 21 CFR 101.30 as an estimate of single-strength sugar content — that acceptance is stated in question 8 of the Q&A guidance, not in the regulation itself. Question 12 adds that it is practical to count all the moisture in the finished formulation toward reconstitution, and that you should account for water lost during baking or drying. The full method is on the concentrates page.
Q8 — Is it made from more than one ingredient?
Chocolate chips, ketchup, barbecue sauce, sweetened yogurt base, bakery premix, sweetened dried cranberries, flavorings. A single Total Sugars figure cannot be split from the outside — you cannot tell from 54g of sugars in chocolate chips how much arrived as cane sugar.
Work these four sources in order:
| Source | Result | |
|---|---|---|
| a | The supplier's declared Added Sugars per 100g | Use it. Keep the specification sheet — it is your record. |
| b | The supplier's formulation breakdown | Run this procedure on their ingredients. |
| c | The ingredient statement lists no added-sugar ingredients | 0g is defensible. Record the reasoning. |
| d | None of the above | Unknown — go to Q9. |
FDA anticipates exactly this: "Manufacturers may need to work with their suppliers to determine the amount of free mono- and disaccharides in ingredients used in a food's formulation" (Q&A guidance, question 2).
Q9 — Nothing resolved it
Record the value as unknown. Do not record it as zero.
A missing value and a zero value are different claims. Zero asserts to the reader and to FDA that no sugar was added; unknown asserts nothing and prompts you to go and find out.
USDA states the same principle for its own data:
"In some cases, values for particular nutrients are missing. This does not indicate a zero value. It means only that the data were not supplied by the data provider."
Absence and zero are different claims, and only one of them is a statement about the food.
An unknown ingredient blocks a defensible declaration. Resolve it with your supplier before the label goes to print.
Recipe-level steps
Once every ingredient has a value, five steps remain.
R1 — Adjust for fermentation or browning
If sugars are consumed during fermentation or reduced by non-enzymatic browning — bread, kombucha, yogurt, beer, caramelization — you have three legally distinct routes under 21 CFR 101.9(g)(10)(v). If you have no data on how much sugar survives your process, declare what you put in — that is Route B, and it needs no testing. See Fermentation and browning.
R2 — Check the ceiling
If your figure exceeds Total Sugars, declare Added Sugars equal to Total Sugars (Q&A guidance, question 21).
This breach almost always comes from a pre-fermentation figure — see Fermentation and browning for why, and for the records that go with each route.
R3 — Scale to the serving, round, and calculate the percent Daily Value
Divide the batch figure by the number of servings. Then round, per 21 CFR 101.9(c)(6)(iii): below 0.5g may be declared 0g; 0.5g to under 1g may state "less than 1 gram"; 1g and above rounds to the nearest gram. Then divide by the Daily Value for the population your product is labeled for — 50g for adults and children 4 and over, or 25g for children 1 to 3 — and express the result to the nearest whole percent. No Daily Value is set for infants under 12 months, so those labels carry the gram amount and no percentage. See FDA Daily Values for the full table.
R4 — Check whether the declaration may be omitted
Under 1g per serving and no claims about sweeteners, sugars, added sugars or sugar alcohols? You may omit it, and then "Not a significant source of added sugars" appears at the bottom of the table. Any qualifying claim removes the exemption.
R5 — Is the product itself a single-ingredient sugar?
If you are labeling honey, maple syrup, agave or sugar sold on its own, the format changes. See Single-ingredient sugars and syrups.
Worked example: blueberry muffins
A batch yielding 12 muffins, with one muffin as the declared serving.
| Ingredient | Grams | Sugars /100g | Total Sugars | Node | Added /100g | Added Sugars |
|---|---|---|---|---|---|---|
| All-purpose flour | 240 | 0.27 | 0.65g | Q6 | 0 | 0g |
| Granulated sugar | 150 | 99.8 | 149.70g | Q3 | 99.8 | 149.70g |
| Honey | 60 | 82.1 | 49.26g | Q3 | 82.1 | 49.26g |
| Whole milk | 240 | 5.05 | 12.12g | Q6 | 0 | 0g |
| Banana, mashed | 200 | 12.2 | 24.40g | Q6 | 0 | 0g |
| Blueberries | 100 | 9.96 | 9.96g | Q6 | 0 | 0g |
| Butter | 113 | 0.06 | 0.07g | Q6 | 0 | 0g |
| Egg | 100 | 0.37 | 0.37g | Q6 | 0 | 0g |
| Batch total | 1,203 | 246.53g | 198.96g |
Per muffin, dividing by 12:
- Total Sugars — 246.53 ÷ 12 = 20.54g → declared 21g
- Added Sugars — 198.96 ÷ 12 = 16.58g → declared 17g
- Percent Daily Value — 16.58 ÷ 50 = 33.16% → declared 33% (50g basis: a general-population product)
- Ceiling check — 17g Added ≤ 21g Total ✓
The label line reads "Includes 17g Added Sugars" at 33% Daily Value.
This example calculates the percent Daily Value from the unrounded 16.58g. Calculating from the declared 17g instead gives 34%. Both are lawful under 21 CFR 101.9(d)(7)(ii) — pick one basis, apply it across your portfolio, and record which you use.
The honey contributes 49.26g rather than 60g, because only its sugar portion counts. The banana and blueberries contribute 34.36g of Total Sugars and nothing to Added Sugars.
A note on ingredient databases
If you are pulling composition values from a public database, check what the Added Sugars field actually contains before you trust it.
USDA's Foundation Foods, SR Legacy and FNDDS datasets carry no added-sugars values at all. The Branded Foods dataset carried them for roughly a third of products when we measured it in 2026, transcribed from manufacturer labels rather than determined — which means single-ingredient honey and sugar entries frequently read zero, for the labeling reason described in Q3.
A database lookup is a starting point for Total Sugars. For Added Sugars, the determination comes from your formulation.
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.