TABLE 7-8 Potential Qualifying Criteria for a Front-of-Package Added Sugars Point for Individual Foods

Total Sugars Content Condition and/or Rationale
0 g on NFP Meets criteria for “sugar free”a
0.5 g per RACC Products with no ingredient recognized as added sugars listed in the ingredients statementb
6 g per ounce Breakfast cereals that meet the WIC requirement for sugarsc
5 g per RACC Products with an ingredient recognized as added sugars except for canned products containing tomatoes and/or other vegetables and yogurt products and substitutesd
10 g per RACC Canned products with tomatoes and other vegetables that contain naturally occurring sugars as well as an ingredient recognized as added sugarse
20 g per RACC Yogurt products and substitutes that contain a low calorie sweetener and an ingredient recognized as added sugarsf

NOTES: LS = labeled serving size, NFP = Nutrition Facts panel, RACC = reference amounts customarily consumed, WIC = Special Supplemental Nutrition Program for Women, Infants and Children.

a Contains <0.5 g sugars per RACC and LS. 21 CFR 101.60(c)(1).

b Applies to products containing only naturally occurring sugars such as fruits, fruit juices, and milk.

c Contains no more than 21.2 g sucrose and other sugars per 100 g of dry cereal. Available online: (accessed March 15, 2011).

d This would qualify WIC-eligible peanut butters and canned mature legumes. The latter contains small amounts of added sugars to prevent stress resulting from the canning process; however, WIC does not specify what constitutes a small amount of sugar. The 5 g represents 20 calories or 1 percent of 2,000 calories. Available online: (accessed March 15, 2011).

e WIC requirements allow small amounts of sugars to be added to vegetables that are naturally sugar-containing during the canning process to prevent stress resulting in membrane rupture; however, WIC does not specify what constitutes a small amount of sugar. The 10 g represents 40 calories or 2 percent of 2,000 calories. Available online: (accessed March 15, 2011).

f Half the sugar should come from milk as estimated from the protein and lactose contents of plain yogurt and products expected to be covered by this criterion.

more foods that are consistent with the Dietary Guidelines recommendations and/or are WIC-eligible to earn an FOP sodium point, as well as foods that have been specially formulated to meet regulations for a “healthy” claim such as some soups and vegetable juices. The qualifying criteria also provide a more realistic target for product reformulation and new product development.

A limitation is that products that pass the eligibility criteria for sodium would automatically qualify for a sodium point based on “healthy,” because the cut-off for qualifying for an FOP sodium point based on “healthy” is the same as the cut-off for eligibility based on the disclosure amount. This limitation could be addressed by reducing the qualifying cut-off for sodium over time as part of an overall strategy to reduce sodium in the food supply.

Qualifying Criteria for Added Sugars

Although added sugars are not declared in the NFP, the committee identified an approach for determining whether a product qualifies for an FOP point for added sugars. The approach uses FDA’s claim criteria for “sugar free” and “no added sugars,” as well as the amount of total sugars declared on the NFP in conjunction with specific conditions. Potential criteria and associated rationale or conditions for individual foods are listed in Table 7-8. Criteria for meal products and main dishes could be developed and evaluated based on a similar approach.

FDA regulations provide for claims of “no added sugars” and “without added sugars” if no sugar or sugar-containing ingredient is added during processing. FDA defines “added sugars” as sugars or other ingredients added during processing or packaging that functionally substitute for sugars, such as fruit juice concentrates, jams, and jellies, and including ingredients that may functionally increase the sugars content of a food, such as enzymes.23

The Dietary Guidelines list the following as examples of added sugars: anhydrous dextrose, brown sugar, con-


23 21 CFR 101.60(c)(2).

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