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.
Honey contributes Added Sugars. That is true in the regulation and true in your formulation. What changes for a jar of honey sold on its own is not whether it counts, but how the panel is written.
Two different questions
"Does honey count as an Added Sugar?" Yes — always. FDA names "sugars from syrups and honey" directly in the definition at 21 CFR 101.9(c)(6)(iii). When you formulate with honey, maple syrup, agave or molasses, 100 percent of their sugars count.
"Must a jar of honey print 'Includes Xg Added Sugars'?" No. Section 12516 of the Agriculture Improvement Act of 2018 removed that requirement for single-ingredient sugars, honey, agave and syrups packaged and sold as a single-ingredient food.
The two questions have different answers. The Farm Bill changed a labeling format. It did not change what honey is.
Which products qualify?
First, what a product qualifies for: permission to leave the words "Includes Xg Added Sugars" off its own Nutrition Facts panel. Nothing else changes. The sugars are still Added Sugars, the percent Daily Value still appears, and the product is still a full Added Sugars contributor in anyone else's recipe.
The statute is one sentence, and it sets two conditions:
The food labeling requirements under section 403(q) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 343(q)) shall not require that the nutrition facts label of any single-ingredient sugar, honey, agave, or syrup, including maple syrup, that is packaged and offered for sale as a single-ingredient food bear the declaration "Includes X g Added Sugars."
So the product must be one of four things — a sugar, honey, agave, or a syrup — and it must be sold as a single-ingredient food. Both conditions, not either.
For the second condition, FDA's guidance gives a test you can apply by reading the label. It uses "pure" and "100%" to mark the boundary, distinguishing qualifying products from "those that cannot properly be labeled 'pure' or '100%' because they contain additional ingredients such as sweeteners or flavorings."
In practice that reduces to the ingredient statement: one ingredient qualifies, two does not.
| Product | Qualifies? | Reason |
|---|---|---|
| Pure honey | Yes | Named in the statute; one ingredient |
| Pure maple syrup | Yes | Named in the statute; one ingredient |
| Granulated, cane or coconut sugar | Yes | A sugar sold as a single-ingredient food |
| Agave syrup | Yes | Named in the statute |
| Molasses, corn syrup, rice syrup | Yes | A syrup sold as a single-ingredient food |
| Brown sugar | Depends on the label | Qualifies if the ingredient statement is one line; a label declaring sugar and molasses is multi-ingredient |
| Powdered sugar containing cornstarch | No | Second ingredient |
| Flavored or infused syrup | No | FDA names flavorings specifically |
| Pancake syrup | No | Corn syrup plus flavoring and color |
| Honey blended with another sweetener | No | Cannot be labeled "pure" |
| Sweetened dried cranberries | Different rule | See Cranberry products below |
Anything in the "No" rows is an ordinary multi-ingredient food: it declares Added Sugars in grams with the percent Daily Value, in the standard format.
This is not one of the four exclusions in the Added Sugars definition. Those decide whether a sugar counts. This decides how a package prints a number that already counts. The statute is titled "Labeling exemption for single ingredient foods and products" — the exemption is from the phrase, not from the nutrient.
What a single-ingredient package must still show
The relief is narrow. FDA's guidance is explicit that these products "are not required to bear the words 'Includes Xg Added Sugars' but must still include the percent Daily Value (DV) for added sugars on their labels."
So a jar of honey shows a percent Daily Value with no gram figure beside it. FDA addresses that gap with a footnote:
we intend to exercise enforcement discretion with respect to the use of a '†' symbol immediately following the added sugars percent DV… The '†' symbol should direct consumers to a statement that is truthful and not misleading within a footnote in the Nutrition Facts label box that includes a description of the gram amount of sugar added to the diet by one serving of the product and its contribution to the percent DV for added sugars in the diet.
Note what the footnote has to say. FDA's enforcement discretion applies to a footnote that gives the gram amount of sugar per serving and its contribution to the Added Sugars percent Daily Value. A bare "† Sugars from honey" does not meet that description.
The symbol and footnote are encouraged, not required. The footnote sits inside the Nutrition Facts box, beneath the standard percent Daily Value footnote.
What a honey label looks like
FDA's own illustration of a pure honey panel, from page 10 of the June 2019 guidance. Serving size is 1 tablespoon (21g):
Total Carbohydrate 17g 6%
Total Sugars 17g
34%†
Protein 0g
─────────────────────────────────────────────
* The % Daily Value (DV) tells you how much a nutrient
in a serving of food contributes to a daily diet. 2,000
calories a day is used for general nutrition advice.
† One serving adds 17g of sugar to your diet and
represents 34% of the Daily Value for Added Sugars.The Added Sugars line carries no name and no gram figure — just the percentage and the dagger, indented under Total Sugars where "Includes 17g Added Sugars" would otherwise sit. The gram amount still reaches the consumer, through the footnote rather than the line.
The arithmetic is unchanged: 21g of honey at 82.1g sugars per 100g rounds to 17g, and 17 ÷ 50 = 34%.
A multi-ingredient product containing that same tablespoon of honey has no such option. It prints "Includes 17g Added Sugars 34%" on the line itself.
Cranberry products are handled differently
Sweetened dried cranberries and cranberry beverages get their own treatment, and it is not the same relief. These products must still declare Added Sugars in grams and show the percent Daily Value — the full "Includes Xg Added Sugars" phrase stays on the label.
Which cranberry products are covered?
Exactly two, and FDA names both:
- Dried cranberries without added flavorings
- Cranberry beverages made of cranberry juice sweetened with added sugars
Both must also clear a quantity condition: the Total Sugars in a serving must not exceed the Total Sugars in a serving of a comparable product with no added sugars.
FDA does not leave "comparable" open. Footnote 3 defines it as a product in the same food category (fruit), in the same form (dried), with the same usage (a snack) — and names the two comparators:
| Your product | FDA's comparable product |
|---|---|
| Sweetened dried cranberries | Unsweetened raisins |
| Sweetened cranberry juice beverage | Unsweetened grape juice |
So a bag of sweetened dried cranberries is measured against raisins. If a serving carries more Total Sugars than a serving of raisins does, the discretion does not apply.
Nothing else is covered. FDA states it is "not aware of products, other than the dried cranberry and cranberry beverage products previously discussed" that meet both conditions, while leaving room to revisit other naturally tart fruits later.
What the cranberry label looks like
Contrast the two panels. Honey drops the phrase; cranberry keeps it and marks the percentage:
Pure honey (1 Tbsp)
Total Sugars 17g
34%†
Cranberry juice beverage (8 fl oz)
Total Sugars 25g
Includes 23g Added Sugars 46%†Both panels come from the June 2019 guidance (page 10 and page 11). The dagger does different work in each: on honey it replaces a missing gram figure, on cranberry it explains a figure that is fully declared.
The two daggers also lead to different places, covered below.
What the statement can say
The statement goes outside the Nutrition Facts box, elsewhere on the package. FDA's wording is that the dagger "should direct consumers to a statement that is truthful and not misleading on the package outside the Nutrition Facts label". Only the dagger itself sits in the panel, immediately after the Added Sugars percent Daily Value.
That is the opposite of the honey case, where the footnote sits inside the box beneath the standard percent Daily Value footnote. Same symbol, different destination.
FDA illustrates four "recommended factual statements", from a bare one to versions citing the Dietary Guidelines:
† Sugars added to improve palatability.
† Sugars added to improve the palatability of naturally tart cranberries.
† Sugars added to improve the palatability of naturally tart cranberries. The 2015-2020 Dietary Guidelines for Americans state that there is room for limited amounts of Added Sugars in the diet, including from nutrient dense foods, like naturally tart fruit.
† Sugars added to improve the palatability of naturally tart cranberries. The 2015-2020 Dietary Guidelines for Americans recommends limiting calories from added sugars to no more than 10% each day.
These four statements are illustrations rather than required wording — the standard is any statement that is truthful and not misleading.
If you buy cranberries as an ingredient
The discretion covers the cranberry package, not products made from it. FDA states it does not extend to "a granola bar or trail mix containing dried sugar-sweetened cranberries." Sweetened dried cranberries arriving in your kitchen are an ordinary multi-ingredient ingredient: the sugar added to them by your supplier is Added Sugars in your product.
Why some data sources report honey as zero added sugars
This rule has a side effect worth knowing about if you take composition values from a database.
Because single-ingredient packages may lawfully omit the gram declaration, records transcribed from those labels frequently carry zero. In a 2026 BetterMenu analysis of USDA's Branded Foods dataset, 14.4 percent of products in the Honey category and 20.5 percent in the granulated, brown and powdered sugar category reported zero Added Sugars.
That zero describes how the package is labeled, not what is in the jar. Read it as a composition value and you will declare zero Added Sugars for a recipe built on honey. When honey is an ingredient in your product, 100 percent of its sugars are Added Sugars regardless of what the supplier's own panel shows.
A conflict between the statute and the regulation
The regulation was never updated to match the Farm Bill.
21 CFR 101.9(c)(6)(iii) still states that Added Sugars content "shall be indented under Total Sugars and shall be prefaced with the word 'Includes'", with no single-ingredient exception anywhere in the text. The relief exists only in Public Law 115-334 §12516 and in the June 2019 guidance.
Anyone reading the CFR alone will conclude that a jar of honey must print "Includes 17g Added Sugars". Anyone reading only the guidance may miss that the percent Daily Value is still mandatory. Both documents are needed to get the panel right.
The June 2019 guidance also misnumbers its own citation, pointing the Added Sugars Daily Value at 21 CFR 101.9(c)(8)(vii) — a paragraph about how to name folate on a label. The Daily Reference Values are at (c)(9).
Where to go next
- Added Sugars under FDA rules — the definition, format and rounding
- How to determine Added Sugars — using honey and syrups as ingredients
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.