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Nutrient Content Claims

Quick answer

Nutrient content claims are words on a food label that describe how much of a nutrient the food has, like "low sodium", "fat free" or "high in fiber". FDA defines each term in 21 CFR 101.54 to 101.67, and every claim follows the general rules in 101.13: the food must meet the number per reference amount, often also per serving or per 50 g, carry a full Nutrition Facts panel, and add extra statements when fat, saturated fat, cholesterol or sodium run high. A claim that FDA has not defined may not be made.

Nutrient content claims on a tub of fresh salsa: "Low sodium" on the front, with the Nutrition Facts panel on the back showing 70 mg sodium per 2 tbsp
The claim on the front, the numbers that back it up on the back
01

What counts as a nutrient content claim

FDA splits these claims in two. An expressed claim states a level directly. An implied claim suggests a level without naming it, through an ingredient or a phrase.

TypeWhat it looks likeFDA's own examples
ExpressedA direct statement about the level of a nutrient"low sodium", "contains 100 calories"
Implied, by ingredientWording that suggests a nutrient is absent or present in a certain amount"high in oat bran"
Implied, by healthy eatingWording that suggests the food helps maintain healthy dietary practices because of its nutrients"healthy"

Numbers inside the Nutrition Facts panel are not claims. Repeat the same number on the front, like "8 g fiber" next to the product name, and it becomes one, with all the rules on this page.

21 CFR 101.13(b)(1), (b)(2), (c)Expressed and implied claims, and when nutrition label information becomes a claim.
02

Nutrient content claim terms and their limits

The limits below are per reference amount customarily consumed (RACC), the FDA amount behind your serving size. "Free" claims must also be met per labeled serving. For foods with a small reference amount, "low" claims are checked per 50 g as well (see the next section).

RACC: FDA Reference Amounts Customarily Consumed →
ClaimMain conditionRule
Calorie freeLess than 5 calories21 CFR 101.60(b)(1)
Low calorie40 calories or less21 CFR 101.60(b)(2)
Fat freeLess than 0.5 g fat, and no added fat ingredient without an asterisk note21 CFR 101.62(b)(1)
Low fat3 g fat or less21 CFR 101.62(b)(2)
Sodium freeLess than 5 mg sodium, and no salt ingredient without an asterisk note21 CFR 101.61(b)(1)
Very low sodium35 mg sodium or less21 CFR 101.61(b)(2)
Low sodium140 mg sodium or less21 CFR 101.61(b)(4)
Reduced, less, fewer (calories, fat, sodium)At least 25% less than a named reference food21 CFR 101.60(b)(4) · 101.61(b)(6) · 101.62(b)(4)
Light, liteOne third fewer calories or 50% less fat; 50% less fat when half or more of the calories come from fat21 CFR 101.56(b)
Good source, contains, provides10 to 19% of the Daily Value21 CFR 101.54(c)
High, rich in, excellent source of20% or more of the Daily Value21 CFR 101.54(b)
More, added, extra, plus, fortified, enrichedAt least 10% of the Daily Value more than a reference food21 CFR 101.54(e)

Each term also covers its synonyms. "Zero fat", "no fat" and "without fat" all fall under fat free, and "few calories" falls under low calorie. Spelling variations like "hi" and "lo" are allowed when they are not misleading.

21 CFR 101.13(b)(4) · 101.54 · 101.56 · 101.60 · 101.61 · 101.62The definitions of each term and the rule on spelling variations.
Sugar free, no sugar added and reduced sugar: Sugar free food labels →
03

Small servings: the per 50 g check

Dips, dressings, sauces and other foods with a reference amount of 30 g or less, or 2 tablespoons or less, get a second test for "low" claims. The food has to meet the limit per reference amount and also per 50 g. Without that rule, a tiny serving could make almost anything look low.

Example with our engine: a fresh salsa of 4 cups chopped tomatoes, 1 cup onion, 2 jalapeños, 1/2 cup cilantro and 2 tbsp lime juice. FDA puts salsa with the dips, at 2 tbsp. We used 36 g for 2 tbsp.

Salt in the batchSodium per 2 tbsp (36 g)Sodium per 50 g"Low sodium"?
1 1/4 tsp110 mg160 mgNo: passes per serving, fails per 50 g
3/4 tsp70 mg95 mgYes: 140 mg or less on both counts

The same per 50 g test applies to "low calorie" (40 calories) and "low fat" (3 g). This salsa has 10 calories per serving and per 50 g, so it is low calorie on both counts.

21 CFR 101.12(b) Table 2 · 101.60(b)(2)(i)(B) · 101.61(b)(4)(i)(B) · 101.62(b)(2)(i)(B)The 2 tbsp reference amount for dips including salsa, and the per 50 g test for low calorie, low sodium and low fat.
Nutrition Facts
about 13 servings per container
Serving size2 tbsp (36g)
Amount per serving
Calories10
% Daily Value*
Total Fat 0g0%
Saturated Fat 0g0%
Trans Fat 0g
Cholesterol 0mg0%
Sodium 70mg3%
Total Carbohydrate 2g1%
Dietary Fiber 0g0%
Total Sugars 1g
Includes 0g Added Sugars0%
Protein 0g
Vitamin D 0mcg0%
Calcium 0mg0%
Iron 0.1mg0%
Potassium 80mg0%
*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: fresh salsa with 3/4 tsp salt, 16 oz tub
04

When the food is "free" or "low" by nature

A "free" or "low" claim in front of the name suggests you changed the recipe to get there, like "low sodium potato chips". If every food of that type already meets the limit, the label has to say so and talk about the whole category, not just your brand.

Our salsa has no added fat and rounds to 0 g, but fresh salsa is fat free by nature. So "fat free salsa" would be misleading; FDA's pattern is "corn oil, a sodium-free food", which here becomes "salsa, a fat free food". The low sodium version is different: you cut the salt to get there, so "low sodium salsa" works.

21 CFR 101.13(e)(1), (e)(2)Free and low claims on specially processed foods, and the wording for foods that meet the criteria by nature.
05

Rules that come with every claim

  • The claim may be at most twice the type size of the product name, and not unduly prominent in style
  • Over the disclosure levels (fat 13 g, saturated fat 4 g, cholesterol 60 mg, sodium 480 mg) per reference amount, per serving, or per 50 g when the reference amount is small: add "See nutrition information for ___ content" in bold, right next to the claim
  • A relative claim (reduced, less, more, light) names the reference food, gives the percentage difference, and compares the amounts per serving
  • You cannot claim "reduced" against a reference food that already qualifies as "low"
  • If your labeled serving differs from the reference amount and the serving alone misses the limit, follow the claim with its criteria, like FDA's example for a drink
  • A Nutrition Facts panel is required on any food with a claim, and the small business exemption from the panel ends
21 CFR 101.13(f), (h)(1), (h)(4), (j)(2), (j)(3), (n), (p) · 101.9(j)(1)(i)Type size, the disclosure statement, relative claim details, serving size criteria, and the nutrition labeling requirement.
21 CFR 101.13(p)(1)"very low sodium, 35 mg or less per 240 milliliters (8 fl oz.)"
06

Plain amounts versus "only"

A plain, accurate amount like "5 grams of fat" needs no disclaimer. Add a word that judges the amount, such as "only", and the statement now implies the food is low. Then it must meet the definition, or carry a disclaimer next to it saying it is not low.

21 CFR 101.13(i)(2)"only 200 mg sodium per serving, not a low sodium food."

"Percent fat free" is not covered by this amount rule. It has its own definition: the food must qualify as low fat, and the percentage and the words "fat free" must be the same type size. "100 percent fat free" also needs less than 0.5 g fat per 100 g and no added fat.

21 CFR 101.13(i)(1) to (i)(4) · 101.62(b)(6)Amount and percentage statements, and the separate rule for percent fat free.
07

Meals, foods for young children and terms FDA never defined

  • Meal products (a serving of 10 oz or more, built from at least three 40 g portions across two or more of four food groups) and main dish products (6 oz or more, with 40 g or more from each of at least two groups) have their own limits, usually per labeled serving
  • For "good source" or "high" on a meal or main dish, name the food in it that qualifies: FDA's example is "the serving of broccoli in this product is high in vitamin C"
  • Foods made specially for children under 2 may not carry nutrient content claims, except vitamin and mineral percentage statements and claims a regulation provides for
  • A nutrient content claim that no regulation defines may not be used. A new one takes a petition to FDA
21 CFR 101.13(b), (b)(3), (l), (m) · 101.54(b)(2) · 101.69Meal and main dish definitions, claims on foods for children under 2, and petitions for new claims.

FDA has also proposed changes to the low sodium and low saturated fat claims as part of its front-of-package nutrition proposal. Until a final rule is published, the definitions above are the ones in force.

Front-of-package nutrition labels: what FDA proposed →
08

What our tool does, and what it leaves to you

Nutrition Label Studio calculates every number on the panel from your recipe with USDA data and FDA rounding, so the figures a claim depends on are there. It does not check claims. To test a claim, compare the numbers with the table above, and for small reference amounts set the serving to 50 g for a moment to see the per 50 g values, as we did for the salsa.

Claims are judged with the same methods as the panel, so borderline cases matter. The calculation report shows every unrounded value per serving, which helps when a number sits right at a limit.

Nutrition Label Documentation: The Calculation Report →
21 CFR 101.13(o)Compliance with nutrient content claims is determined with the methods used for nutrition labeling.
Make your label from a recipe →
09

Nutrient content claim checklist

0 of 7 checkedSaved on this device
10

Official sources

21 CFR 101.13, nutrient content claims: general principles (ecfr.gov) →21 CFR Part 101, Subpart D, specific requirements for nutrient content claims (ecfr.gov) →FDA: Label Claims for Conventional Foods and Dietary Supplements (fda.gov) →
Questions

Questions

Any statement outside the Nutrition Facts panel that describes the level of a nutrient, directly ("low fat", "100 calories") or by suggestion ("high in oat bran"). Words like "low", "high" or "good source" must match an FDA definition. A plain, accurate amount like "100 calories" is allowed as long as it does not suggest the food is low or high in it.

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