United States: Fermentation and browning
When yeast eats the sugar you added, what do you declare? FDA gives three routes.
You add 15g of sugar to a batch. The yeast eats some of it, and 12g are left. What goes on the label — what you added, or what remains? FDA lets you choose, but each choice comes with a different record.
Why this case is different
For most foods, the Added Sugars declaration is the sum of what you put in. Fermentation and non-enzymatic browning break that assumption: sugar you genuinely added is genuinely gone by the time the product ships.
FDA's starting position is that the amount added before processing is usually good enough:
Therefore, we expect that the majority of manufacturers would be able to use the amount of added sugars added as an ingredient as a reasonable approximation of the amount of added sugars in a serving of their product.
The paragraph immediately after sets the condition on taking the lower figure:
If a manufacturer has a basis on which to support a declaration of added sugars based on the amount of added sugars present in a food after non-enzymatic browning or fermentation, the label declaration must be supported by records demonstrating the accuracy of the declared amount.
So declaring the higher, pre-process figure is always available and needs less proof. Declaring the lower, post-process figure is permitted but you have to earn it.
Which products does this cover?
Fermentation: bread and yeast-leavened baked goods, kombucha, yogurt, beer, wine, vinegar, fermented vegetables.
Non-enzymatic browning: caramelization, Maillard browning, and ingredients such as burnt-sugar coloring where sugar is consumed by the reaction.
What are the three routes?
FDA codifies exactly three options at 21 CFR 101.9(g)(10)(v).
Route A — declare what remains, with evidence
Declare the post-fermentation amount. You must make and keep records of all relevant scientific data and information demonstrating the amount remaining, plus a narrative explaining why that data is sufficient — and the data must be specific to your type of food.
Test results alone do not satisfy this route. FDA requires the written reasoning for why those results support the amount you declared, alongside the data itself.
Route B — declare what you added
Declare the amount of Added Sugars present before and during processing. Records are simpler: what went in, and what was packaged. The declared figure will be higher, and it may never exceed the Total Sugars on your label.
Take this route if you have not measured what survives fermentation. It requires no testing, and the higher figure is always permitted.
Route C — petition FDA
Submit a petition under 21 CFR 10.30 for an alternative means of compliance. This route is for cases where reduction is significant enough to affect the declaration and you cannot reasonably approximate the finished amount. The petition must explain why, and describe the process by which you reached that conclusion.
The ceiling rule
Added Sugars can never exceed Total Sugars. Where a pre-fermentation figure would, FDA's guidance resolves it directly:
The added sugars declaration should not exceed the total sugars declaration… you should declare the same amount for added sugars as the amount of total sugars obtained through analytical testing for a serving of the food.
— FDA Q&A guidance (November 2018, revised December 2019), question 21
A pre-fermentation figure is the usual way this breach happens, because you are declaring sugar that is no longer there to measure. Run the check before you print, not after.
Specific products
Bread and baked goods
Sugar added to feed yeast during leavening is partly consumed. FDA permits declaring the post-fermentation amount under Route A (question 20), with data specific to your type of baked good and the accompanying narrative.
Kombucha and fermented beverages
Where a fermented beverage contains only sugars meeting the Added Sugars definition — table sugar fed to a culture, with no fruit or dairy sugars present — the amount remaining after fermentation is declared as both Total Sugars and Added Sugars (question 18). The two numbers are the same.
This case is common enough that Kombucha Brewers International publishes standing guidance for its members, recommending post-fermentation laboratory testing with documented records. A worked example in that guidance: 15g of sugar before fermentation, 12g measured after, declared as 12g Total Sugars and 12g Added Sugars.
Caramel and browned ingredients
Where sugar is consumed by non-enzymatic browning, you may declare the residual amount that is analytically detectable in the finished product (question 19), keeping the analytical results and a narrative.
Note a distinction that causes confusion: caramel color manufactured as a color additive is not the same as burnt sugar used as an ingredient. Check what your specification actually describes.
Vinegar
Most vinegars retain no sugars and require no Added Sugars declaration. Balsamic-type products made with grape must are different, because grape must is a concentrated juice — and barrel aging removes water, which concentrates it further.
Yogurt
Sweetened yogurt contains both added and naturally occurring sugars, so the analytical compliance route at 21 CFR 101.9(g)(5) does not apply to its Added Sugars declaration. FDA works this through with yogurt as its example in question 17, and verifies through your records instead.
Choosing a route
| Route A | Route B | |
|---|---|---|
| Declared figure | Lower — what remains | Higher — what you added |
| Records needed | Scientific data specific to your food type, plus a written narrative | What was added before and during processing |
| Testing required | Usually yes | No |
| Best when | You have fermentation data and the reduction is material | You want a defensible number without a testing program |
Whichever you pick, the choice itself belongs in your records. See Recordkeeping.
Where to go next
- How to determine Added Sugars — the full procedure, of which this is step R1
- Recordkeeping — what each route requires you to keep
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.
United States: Single-ingredient sugars and syrups
How honey, maple syrup and pure sugar declare Added Sugars — and why the answer changes when they become an ingredient.
United States: Recordkeeping for Added Sugars
Records are how FDA verifies Added Sugars. Failing to keep them is itself misbranding.