Added Sugars on Nutrition Label: FDA Requirements

Added sugars on nutrition label panels are calculated from your formulation, not measured separately by an instrument, which means two foods with identical total sugars can legitimately report very different added sugars. The line tells the consumer how much sugar was added during processing or falls within FDA's definition of added sugars, rather than how much total sugar the finished food contains.

This guide covers where the requirement comes from, what counts as added sugar, how to round the grams and calculate percent Daily Value, when the line can be omitted, the special treatment for single-ingredient sugars and syrups, and which current FDA actions remain proposals.

It is written for someone producing a compliant panel. For the reference number itself, see the added sugars Daily Value. For the distinction that causes problems on many first labels, see total sugars versus added sugars. For the syrup carve-out, see is honey an added sugar. This guide does not repeat the full Nutrition Facts panel layout.

Why added sugars on nutrition label panels became mandatory

Added sugars were introduced by the 2016 Nutrition Facts final rule, "Food Labeling: Revision of the Nutrition and Supplement Facts Labels," published at 81 FR 33742 on 27 May 2016.

The rule renamed the former "Sugars" row "Total Sugars" and added the indented "Includes Xg Added Sugars" line beneath it.

The requirement is codified at 21 CFR 101.9(c)(6)(iii). It is a binding regulation, not guidance or a proposal.

Firms with $10 million or more in annual food sales had to comply by 1 January 2020. Firms below that threshold had until 1 January 2021. Both dates extended the original 2018 and 2019 deadlines, and both have long passed. A panel printed today therefore needs the line regardless of company size.

The distinction exists because Total Sugars alone cannot distinguish plain milk from a sweetened milk drink. Lactose and fruit sugars arrive with water, fiber and micronutrients. Sucrose stirred into a batch does not.

The 50 g Daily Value for added sugars

The Daily Reference Value for added sugars is 50 g per day for adults and children 4 and older, as established in the table at 21 CFR 101.9(c)(9).

That amount represents 10 percent of a 2,000 calorie reference intake. At 4 calories per gram of carbohydrate, 200 calories equals 50 g.

Every added sugars percent Daily Value on a general-audience Nutrition Facts label is calculated against that 50 g value. The reference changes for younger age groups, which matters when you label foods for toddlers.

Population group	Added sugars DV	Calorie basis
Adults and children 4 and older	50 g	2,000 calories
Children 1 through 3 years	25 g	1,000 calories
Infants through 12 months	None (N/A)	n/a
Pregnant and lactating women	50 g	2,000 calories

Foods for infants through 12 months declare added sugars in grams but do not show a percent Daily Value and carry no footnote.

On a two-age-group label, the 25 g and 50 g bases operate separately. Our Daily Value calculator handles both.

What counts as added sugar under FDA requirements

The operative definition from 21 CFR 101.9(c)(6)(iii) states:

"Added sugars are either added during the processing of foods, or are packaged as such, and include sugars (free, mono and disaccharides), sugars from syrups and honey, and sugars from concentrated fruit or vegetable juices that are in excess of what would be expected from the same volume of 100 percent fruit or vegetable juice of the same type, except that fruit or vegetable juice concentrated from 100 percent juices sold to consumers, fruit or vegetable juice concentrates used towards the total juice percentage label declaration under 101.30 or for Brix standardization under 102.33(g)(2), fruit juice concentrates which are used to formulate the fruit component of jellies, jams, or preserves in accordance with the standards of identity in 150.140 and 150.160, or the fruit component of fruit spreads shall not be labeled as added sugars."

That definition contains four exemptions. Applied to a bill of materials:

Counts as added sugars	Does not count as added sugars
Sucrose, dextrose, glucose, fructose, high fructose corn syrup, corn syrup, invert sugar	Lactose naturally present in milk and dairy ingredients
Brown sugar, cane sugar, evaporated cane juice, coconut sugar, molasses	Sugars in whole fruit and vegetables, including dried and canned
Malt syrup, rice syrup, agave	Sugars in 100 percent fruit or vegetable juice
Honey and maple syrup used as ingredients, or packaged as such	Concentrate reconstituted to 100 percent juice, or used for the juice percentage declaration under 101.30 or Brix standardization under 102.33(g)(2)
Juice concentrate used as a sweetener, to the extent it exceeds what the same volume of 100 percent juice of that type would give	Concentrate forming the fruit component of jams, jellies and preserves under 150.140 and 150.160, or of fruit spreads
A single-ingredient package such as table sugar or a jar of honey, being "packaged as such"	Sugar alcohols and non-nutritive sweeteners, because they are not sugars

Fruit juice concentrate creates some of the most difficult classification questions.

When concentrate is added to sweeten a product, the portion above what the same volume of 100 percent juice of that type would provide is added sugar. Concentrate diluted back to single strength, used to reach a Brix target, or used toward a juice percentage declaration is not.

The jam and jelly exemption is tied to specific standards of identity. Do not extend that carve-out to a generic fruit filling.

How the added sugars nutrition label line appears

The added sugars nutrition label entry appears immediately below Total Sugars. It is double-indented and begins with "Includes."

The standard presentation is "Includes 10g Added Sugars", with percent Daily Value in the right-hand column on the same line.

The nutrient name must be "Added Sugars." Do not change it to "added sugar" or "sugars added."

For small-package and dual-column formats, 21 CFR 101.9(j)(13)(ii)(B) permits "Incl." instead of "Includes."

That is the permitted abbreviation. "Added Sugars" itself cannot be shortened simply because the panel has limited space.

Added sugar label rounding and percent Daily Value

Added sugar grams on the Nutrition Facts label are expressed to the nearest gram.

Below 1 g, you may state "Contains less than 1 gram" or "less than 1 gram." Below 0.5 g, the amount may be expressed as 0 g.

These requirements are part of the broader rules covered in FDA rounding rules, and they are separate from calculating percent Daily Value.

Analytical or calculated amount	Declared grams	Percent Daily Value against 50 g
0.3 g	May be declared 0 g	0 percent
0.7 g	Less than 1 gram	1.4 percent, declared as 1 percent
2.4 g	2 g	4 percent from 2 g, or 5 percent from 2.4 g
9.4 g	9 g	18 percent from 9 g, or 19 percent from 9.4 g
12 g	12 g	24 percent

Under 21 CFR 101.9(d)(7)(ii), you may calculate %DV by dividing either the declared rounded amount or the actual unrounded amount by 50 g, then expressing the result to the nearest whole percent.

Those methods do not always produce the same result. For example, the 9.4 g row produces 18 percent using one method and 19 percent using the other.

Both approaches are defensible. Choose one basis, document it, and apply it consistently across your portfolio.

Worked added sugar label example

Consider a 170 g labeled serving of strawberry yogurt with these ingredients: cultured nonfat milk, strawberries, cane sugar, water, food starch, natural flavor and pectin.

The figures below are illustrative rather than FDA data, but the calculation method is the one you would apply using your supplier specifications.

Ingredient	Sugars contributed per serving	Added or naturally occurring
Cultured nonfat milk (lactose)	8.0 g	Naturally occurring
Strawberries (whole fruit)	1.5 g	Naturally occurring
Cane sugar	9.4 g	Added
Total	18.9 g	9.4 g of it added

Total Sugars is 18.9 g, which rounds to 19 g. Added sugars is 9.4 g, which rounds to 9 g.

Using the declared amount, divide 9 g by the 50 g Daily Value. The result is 18 percent.

The panel therefore reads "Total Sugars 19g", with "Includes 9g Added Sugars 18%" indented below it.

The naturally occurring 9.5 g does not receive its own line. The reader can infer it by subtracting added sugars from total sugars.

A 40 g granola bar containing oats, honey, brown rice syrup and raisins follows the same principle.

Assume honey contributes 4 g of sugars, rice syrup contributes 3 g and raisins contribute 5 g. Honey and rice syrup are added sugars because they are added ingredients. Raisins are whole dried fruit, so their sugars are naturally occurring.

Total Sugars is therefore 12 g. Added sugars is 7 g. Dividing 7 by 50 gives a 14 percent Daily Value.

When the added sugars line may be omitted

The added sugars declaration is not required when the product contains less than 1 g of added sugars per serving and you make no claims about sweeteners, sugars, added sugars or sugar alcohols.

Both conditions must be satisfied.

A savory cracker containing 0.4 g of added sugars can omit the line. Put "no sugar added" on the front of that same product and the omission is no longer available.

If you omit the line, the footnote "Not a significant source of added sugars" must appear at the bottom of the Nutrition Facts table.

The obligation therefore does not disappear. It moves to the footnote.

Foods using the simplified format under 21 CFR 101.9(f), which is available when 8 or more of the 15 listed nutrients are present in insignificant amounts, are handled under that section instead.

Total Sugars has a parallel rule with the footnote "Not a significant source of total sugars."

Many manufacturers simply retain both rows and declare 0 g because the required footnote can consume as much space as the row itself. The added sugars labeling requirements walkthrough covers that decision case by case.

Honey, maple syrup, table sugar and cranberries

A jar of pure honey is entirely added sugars under the "packaged as such" provision. That created an unusual labeling problem because "Includes 17g Added Sugars" on a single-ingredient jar of honey can imply that someone added another ingredient.

FDA addressed this in final guidance issued 18 June 2019, "The Declaration of Added Sugars on Honey, Maple Syrup, Other Single-Ingredient Sugars and Syrups, and Certain Cranberry Products."

Under that guidance, pure honey, pure maple syrup and other single-ingredient sugars and syrups, including table sugar and agave, are not required to declare the gram amount on the "Includes ... Added Sugars" line.

The percent Daily Value is still required.

That distinction is important. Removing the gram amount does not remove the row.

FDA also permits, and encourages, an optional dagger symbol immediately after the percent Daily Value. It can point to a footnote explaining how much added sugar one serving contributes and what percentage of the Daily Value that represents.

Certain cranberry products, including dried cranberries and cranberry juice cocktail, with sugars added for palatability at total sugar levels comparable to similar products, must still declare grams and percent Daily Value. They may, however, add a footnote explaining that the sugars improve the palatability of naturally tart cranberries.

There are two caveats.

First, this is guidance. It is nonbinding, reflects enforcement discretion, and is not codified in 101.9.

Second, the transitional enforcement discretion for these products ran only through 1 July 2021. That transition period has ended, although the guidance still applies.

Added sugars recordkeeping and what is still proposed

Added sugars carry an explicit recordkeeping obligation because the amount cannot be verified analytically.

A laboratory can measure the sugars in your yogurt, but it cannot determine which sugar molecules originated in milk and which came from cane sugar.

Under 21 CFR 101.9(g)(10) and (11), you must keep records supporting the declared amount when:

• A food contains both naturally occurring and added sugars.
• Added sugars are subject to fermentation or non-enzymatic browning, the Maillard reaction.

Bread, yogurt and products involving a browning step can therefore fall within these requirements. Recipes, formulations and batch records are the usual supporting evidence.

Two developments involving added sugars are sometimes described as though they were already law. They are not.

• There is currently no "low added sugars" and no "reduced added sugars" nutrient content claim. FDA's Unified Agenda lists RIN 0910-AJ20, "Nutrient Content Claims for Added Sugars," at the Proposed Rule Stage. It would update the claim provisions and create a voluntary "low added sugar" claim. Its projected proposed-rule date is December 2026. Nothing has been published, so neither phrase is a permitted claim today. The claim validator lists the sugar claims that are defined.
• Added sugars are one of three nutrients in FDA's proposed front-of-package "Nutrition Info" box, together with saturated fat and sodium. As proposed, 20 percent Daily Value or more would be labeled "High." For added sugars, that equals 10 g or more per serving. The rule is proposed, not final, and no packaged food is currently required to carry the box. See the front-of-package proposal for its current status.

Applied to the yogurt example, 18 percent DV would fall within the proposed "Med" band. One additional gram of cane sugar would reach the proposed 20 percent "High" threshold.

If the proposal is ever finalized, reformulation pressure will cluster at 10 g per serving.

To calculate the grams, rounding and percent Daily Value without checking each step manually, build your panel in the Nutrition Facts label generator. It applies the 50 g and 25 g Daily Values by age group, blocks added sugars from exceeding total sugars, and formats the "Includes" and "Incl." variants for standard, small-package and dual-column layouts.

Added sugars on nutrition label: frequently asked questions

Can added sugars ever be higher than total sugars?

No. Added sugars are a subset of Total Sugars, so the declared amount must be less than or equal to declared Total Sugars. An inversion usually comes from double counting a syrup already included in the Total Sugars analysis or calculating the two rows from different source data. Rounding both values from the same underlying analysis resolves most cases.

Do sugar alcohols or stevia count toward added sugars?

No. Sugar alcohols such as erythritol, maltitol and sorbitol are not sugars, and neither are non-nutritive sweeteners. They are excluded from both Total Sugars and Added Sugars declarations. Sugar alcohols have their own Nutrition Facts line, which becomes mandatory when a claim about them is made.

My product has 0.4 g of added sugars. What do I print?

You have two compliant options. You can declare 0 g on the "Includes" line because amounts below 0.5 g may be expressed as 0 g. Or, if you make no claim about sweeteners, sugars, added sugars or sugar alcohols, omit the line and use "Not a significant source of added sugars" at the bottom of the table.

Is fruit juice concentrate in my bar an added sugar?

It depends on its function. When concentrate is used as a sweetener, sugars exceeding what the same volume of 100 percent juice of that type would provide are added sugars. If it is reconstituted to 100 percent juice, used toward the juice percentage declaration under 101.30, or used for Brix standardization under 102.33(g)(2), it is not. Keep records showing how you classified it.

Can I say "no added sugar" instead of declaring the added sugars line?

No. They serve different purposes, and making the claim affects whether you can omit the line. Any claim about sweeteners, sugars, added sugars or sugar alcohols removes the less-than-1-gram omission option. Separately, "low added sugars" and "reduced added sugars" are not currently defined claims, so neither can be used regardless of the formulation.