8 min read

FDA Healthy Claim

Quick answer

FDA healthy claim rules, in the updated 21 CFR 101.65(d), let a food say "healthy" when it contains a set amount from at least one food group (vegetables, fruit, whole grains, fat-free or low-fat dairy, or protein foods) and stays under limits for added sugars, sodium and saturated fat. Plain vegetables, fruit, whole grains, nuts, seeds, eggs, seafood and similar foods with nothing added except water qualify automatically, and so do water, tea and coffee under 5 calories.

FDA healthy claim on a pouch of oat and almond muesli, with "healthy" printed under the product name and 0 g added sugars on the back panel
A food group, three limits, and the records to prove it
01

Which words count as the "healthy" claim

The rule covers "healthy" and its derivatives when they suggest the food helps build a diet that matches dietary recommendations. "Healthier" on a front panel follows the same definition as "healthy".

21 CFR 101.65(d)(3)"You may use the term "healthy" or derivative terms "health," "healthful," "healthfully," "healthfulness," "healthier," "healthiest," "healthily," and "healthiness" as an implied nutrient content claim on the label or in labeling of a food that is useful in creating a diet that is consistent with dietary recommendations if the food meets the criteria of one or more of the following paragraphs (d)(3)(i) through (vi) of this section"
02

Six ways a food can qualify

PathWho it is forChecked
Foundation foodsFoods made only of vegetables, fruit, whole grains, fat-free or low-fat dairy, lean meat, seafood, eggs, beans, peas, lentils, nuts or seeds, with nothing added except waterQualifies as is
Individual food, larger reference amountOne food group, reference amount over 50 g or over 3 tbspPer reference amount
Individual food, small reference amountOne food group, reference amount of 50 g or less, or 3 tbsp or lessPer 50 g of food
Mixed productAt least 1 food group equivalent in total, with at least 1/4 from two groupsPer reference amount
Main dishAt least 2 food group equivalents, with at least 1/2 from two groupsPer labeled serving
MealAt least 3 food group equivalents, with at least 1/2 from three groupsPer labeled serving
Water, tea and coffeeLess than 5 caloriesPer reference amount and per serving
21 CFR 101.65(d)(3)(i) to (vi)The six sets of criteria for the healthy claim.
03

How much food is one food group equivalent

Food group1 food group equivalentFDA's examples
Vegetable1/2 cup equivalent1/2 cup cooked green beans; 1 cup raw spinach
Fruit1/2 cup equivalent1/2 cup strawberries; 1/2 cup 100% orange juice; 1/4 cup raisins
Grains3/4 oz equivalent whole grain1 slice of bread; 1/2 cup cooked brown rice
Dairy2/3 cup equivalent2/3 cup fat free milk; 1 oz nonfat cheese
Game meat1 1/2 oz equivalent1 1/2 oz venison
Seafood1 oz equivalent1 oz tuna
Egg1 oz equivalent1 large egg
Beans, peas, lentils1 oz equivalent1/4 cup black beans
Nuts, seeds, soy products1 oz equivalent1/2 oz walnuts
21 CFR 101.65(d)(2), Table 1Food group equivalents and FDA's examples.
04

Limits for added sugars, sodium and saturated fat

Individual foodMust contain at leastAdded sugars at mostSodium at mostSaturated fat at most
Vegetable product1/2 cup eq. vegetable2% DV10% DV5% DV
Fruit product1/2 cup eq. fruit2% DV10% DV5% DV
Grain product3/4 oz eq. whole grain10% DV10% DV5% DV
Dairy product2/3 cup eq. dairy5% DV10% DV10% DV
Game meat1 1/2 oz eq.2% DV10% DV10% DV
Seafood1 oz eq.2% DV10% DV5% DV, not counting fat inherent in seafood
Egg1 oz eq.2% DV10% DV10% DV
Beans, peas, lentils1 oz eq.2% DV10% DV5% DV
Nuts, seeds, soy products1 oz eq.2% DV10% DV5% DV, not counting fat inherent in nuts, seeds and soybeans
100% oilNone0% DV0% DV20% of total fat
Oil-based spread (fat only from oil)None0% DV10% DV20% of total fat
Oil-based dressing (at least 30% oil)None2% DV10% DV20% of total fat

FDA's own conversions: 2% DV of added sugars is 1 g, 5% is 2.5 g and 10% is 5 g. 10% DV of sodium is 230 mg. 5% DV of saturated fat is 1 g and 10% is 2 g.

Combination foodAdded sugars at mostSodium at mostSaturated fat at most
Mixed product (per reference amount)10% DV15% DV10% DV
Main dish (per labeled serving)15% DV20% DV15% DV
Meal (per labeled serving)20% DV30% DV20% DV

For the three combination foods, saturated fat that is inherent in seafood, nuts, seeds and soybeans does not count toward the limit.

21 CFR 101.65(d)(3)(ii) to (v), Tables 2 to 6 · FDA, Use of the "Healthy" Claim on Food LabelingThe limits per food type and FDA's gram conversions.
05

Example: the same oats, two different answers

Both recipes start with 3 cups rolled oats, 1/2 cup almonds and 1/2 cup raisins. Breakfast cereal that weighs 43 g or more per cup has a 60 g reference amount, so we used a 60 g serving.

RecipePathAdded sugars per 60 gHealthy?
Muesli: oats, almonds, raisins, nothing elseFoundation foods: whole grain, nuts and fruit with nothing added0 g (0% DV)Yes, without checking limits
Granola: the same plus 1/4 cup brown sugar, 1/4 cup canola oil, 1/2 tsp saltMixed product or grain product: limits apply6 g (12% DV)No: added sugars are over 10% DV
Granola with 2 tbsp brown sugar insteadSame3 g (6% DV)Passes the added sugars limit

The lighter granola still has two more checks. Sodium is 150 mg (7% DV), under both the grain limit of 10% and the mixed product limit of 15%. Saturated fat shows as 1 g (5% DV), which is right at the 5% grain product limit, so look at the unrounded value in the calculation report before you decide. The serving must also hold the food group equivalents, and your recipe records have to show that.

21 CFR 101.12(b) Table 2 · 101.65(d)(3)(i), (d)(3)(ii)(A), (d)(3)(iii)The 60 g reference amount for ready-to-eat cereal weighing 43 g or more per cup, and the healthy criteria used here.
Nutrition Facts
about 6 servings per container
Serving size1/2 cup (60g)
Amount per serving
Calories270
% Daily Value*
Total Fat 14g18%
Saturated Fat 1g5%
Trans Fat 0g
Cholesterol 0mg0%
Sodium 150mg7%
Total Carbohydrate 34g12%
Dietary Fiber 5g18%
Total Sugars 10g
Includes 3g Added Sugars6%
Protein 6g
Vitamin D 0mcg0%
Calcium 50mg4%
Iron 1.8mg10%
Potassium 250mg6%
*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.
Example: granola with 2 tbsp brown sugar, 12 oz bag
06

What the update changed

The earlier definition limited total fat, saturated fat, cholesterol and sodium, and asked for 10% DV or more of one or more of these: vitamin A, vitamin C, calcium, iron, protein, fiber. The updated one swaps that for food groups plus limits on added sugars, sodium and saturated fat.

Now qualifies, per FDANo longer qualifies, per FDA
WaterFortified white bread
AvocadosHighly sweetened yogurt
Nuts and seedsHighly sweetened cereal
Higher fat fish, such as salmon
Olive oil
FDA, Use of the "Healthy" Claim on Food LabelingThe previous criteria and FDA's examples of foods that gain or lose the claim.
07

Old or new definition: which one applies to your label

eCFR now shows only the updated criteria. But FDA gave manufacturers a compliance period of three years from the rule's effective date, and said it will not enforce the new criteria before that compliance date. Until then, a label may follow either definition. Compliance is judged by the date the label is put on the product.

Final rule, Food Labeling: Nutrient Content Claims; Definition of Term "Healthy", Response 134"manufacturers could either comply with the new requirements or continue to use the original definition of "healthy" until the compliance date."

One FDA page still lags behind: its general overview of label claims describes "healthy" in terms of total fat, saturated fat, cholesterol and sodium, which is the earlier definition. For anything you print for the long run, go by 21 CFR 101.65(d) as it stands now.

There is no official "healthy" symbol yet. FDA has been researching one and says:

FDA, Use of the "Healthy" Claim on Food Labeling"The FDA continues to work on development of the symbol."
08

Records you must keep

If your ingredient list and label don't already prove the food group equivalents, you must keep written records that do: recipes, formulations, database analyses or batch records. Keep them for two years or more after the food is introduced into interstate commerce, and make them available to FDA when asked, including during an inspection.

Foundation foods with nothing added, and water, tea and coffee, don't need these records.

Two more rules: a food labeled "healthy" needs a Nutrition Facts panel, and the "See nutrition information for ___ content" statement that other nutrient claims trigger does not apply to the healthy claim.

21 CFR 101.65(d)(4) · 101.65(a)(2), (a)(3)The records requirement, the exception from 101.13(h), and the nutrition labeling requirement.

Our calculation report, with your recipe, each ingredient's USDA match and the rounding behind every number, makes a good start for these records. The food group equivalents are still yours to document.

09

What our tool checks for an FDA healthy label

Nutrition Label Studio gives you added sugars, sodium and saturated fat with their % Daily Values, so the three limits are a quick comparison. It does not check the healthy claim or count food group equivalents, and it does not print the word "healthy" on your label. That goes on your artwork once you have confirmed the food qualifies.

Check your numbers: make a label from your recipe →
10

Healthy claim checklist

0 of 6 checkedSaved on this device
11

Official sources

21 CFR 101.65, implied nutrient content claims (ecfr.gov) →FDA: Use of the "Healthy" Claim on Food Labeling (fda.gov) →
Questions

Questions

It is an FDA-defined claim. The food must contain a set amount from at least one recommended food group and stay under limits for added sugars, sodium and saturated fat, or be a plain food like fruit, vegetables, nuts or fish with nothing added but water.

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