Added Sugars Jesse Zuehlke, PhD Food Label Conference
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Added Sugar Fructose Glucose Sucrose Maltose Lactose 3
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Added Sugars - New Nutrient Declared as Includes Xg Added Sugars Indented under Total Sugars Need to verify declaration with records % DV for Added Sugars is based on 50 g 5
Added Sugar 21 CFR 101.9(c)(6)(iii) (iii) Added Sugars : A statement of the number of grams of added sugars in a serving, except that label declaration of added sugars content is not required for products that contain less than 1 gram of added sugars in a serving if no claims are made about sweeteners, sugars, added sugars, or sugar alcohol content. If a statement of the added sugars content is not required and, 897 as a result, not declared, the statement Not a significant source of added sugars shall be placed at the bottom of the table of nutrient values in the same type size. 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) of this chapter, fruit juice concentrates which are used to formulate the fruit component of jellies, jams, or preserves in accordance with the standard of identities set forth in 150.140 and 150.160 of this chapter, or the fruit component of fruit spreads shall not be labeled as added sugars. Added sugars content shall be indented under Total Sugars and shall be prefaced with the word Includes followed by the amount (in grams) Added Sugars ( Includes X g Added Sugars ). It shall be expressed to the nearest gram, except that if a serving contains less than 1 gram, the statement Contains less than 1 gram or less than 1 gram may be used as an alternative, and if the serving contains less than 0.5 gram, the content may be expressed as zero. When a mixture of naturally occurring and added sugars is present in the food, and for specific foods containing added sugars, alone or in combination with naturally occurring sugars, where the added sugars are subject to fermentation and/or non-enzymatic browning, the manufacturer must make and keep records in accordance with paragraphs (g)(10) and (11) of this section to verify the declared amount of added sugars in the label and labeling of food. 6
Added Sugar Definition + Intrinsic Sugar Added Sugar Added during processing or packaged as such Total Sugar Sum of all free mono- and disaccharides Ingredient Statement: Sugar, Fructose, Dextrose, Lactose, High Fructose Corn Syrup, Cane Syrup, Rice Syrup, Molasses, Brown Sugar, Confectioner s Sugar, Tapioca Syrup, Invert Sugar, Honey, Maple Syrup, Agave, Malt Syrup 7
Added Sugars Must be labeled as Added Sugars: Sugars added during processing Sugars (free mono- and disaccharides) Syrups Honey Concentrated Fruit / Vegetable Juice** Concentrated Fruit / Vegetable Puree, etc** 8
Added Sugar Do not need to be labeled as Added Sugars: Concentrated juices used in jellies, jams, or preserves formulated in accordance with the Standard of Identity Un-concentrated fruit or vegetable juices Sugar Alcohols Low-Calorie Sweeteners May be expressed as zero: If serving is < 0.5 gram
Added Sugar Fermentation All Added Sugar Item Post Ferment: Added = Total Added + Intrinsic Sugar Item Reasonable approximation Added Sugars Total Sugars Documentation Analytical Data Narrative Substantiation
Added Sugar Non-enzymatic Browning Caramelization Oxidation of sugar polymers Ingredients used for color or flavor Maillard Browning Reducing Sugar + amino acid reaction Documentation Analytical sugar quantity may be declared
Added Sugar Hydrolysis Hydrolysis Complex Carbohydrates mono- or di-saccharides FDA to consider intent of the hydrolysis: incidental vs for sweetness Maltodextrin / Corn Syrup Solids Maltodextrins (DE < 20) Corn Syrup Solids (DE 20) FDA Guidance If a Serving of the food contains <0.5g added sugars from hydrolysis; this quantity would be considered insignificant and added sugars may be expressed as 0.
Added Sugar Fruit and Vegetable Products Puree Puree Concentrate Dried Fruit / Vegetable Fruit / Vegetable Powder All components of a whole fruit or vegetable broken down into smaller pieces Pulp from the fruit has been removed Sugars have been concentrated Processing and final constituency of the item will be considered by FDA water removed Concentrated source of sugars contributes additional calories to a food
Total vs Added Sugars Other Total Sugar Added Sugar Sugar (examples) Syrups (honey, maple ) Water Added Sugar Added Sugar Fruit Juice (100%) Water, misc. Fruit Sugar Juice & Puree Concentrates Water, misc. Fruit Juice Added Sugar Jam misc. Fruit Sugar Added Sugar Artificial sweeteners misc. 14
Added Sugar Intrinsic Sugar Total vs Added Sugars Fruit Concentrated Juice Jam Food Product Sugar Sugar Sugar Sugar Sugar Added Sugar Added Sugar Added Sugar Added Sugar
Record Requirements Added Sugars, Dietary Fiber, Folate & Vitamin E Sufficient documentation is required upon request Two year window Added vs Total verification Processing Reductions 16
Record Requirements Quantitative Statement Allowable Variation? Can I under-declare Added Sugar by 20% in accordance with my GMPs? 100% Total Intrinsic Sugar 20% overage for the Total Sugars Mixture of Added and Intrinsic Sugar 20% overage for the Total Sugars Record Requirements for Added Sugars 100% Added Sugar Record Requirements for Added Sugars
Nutrient Content Claims No Added Sugar No sugars or ingredients which contain sugars No jam, jelly, or concentrated fruit juice low / reduced sugar disclosure 0g Added Sugar per serving Statement of Fact New NFP General Disclosure Statement
Case Studies Coca Cola Dried Blueberries Toaster Pastries (Reformulation) Cake Bites (RACC designation) Hershey s?
Product Impact of Nutrition Label Reform Coca Cola Example Per Container Labeling High Calories High Added Sugars 12 fl. oz. 16 fl. oz. 20 fl. oz. 33.8 fl. oz.
Coca-Cola Says Its Mini Cans Are Reinventing The Soda Business They might just look like tiny Coke cans, but to the company, they re a significant and strategic re-architecture of our packaging mix. As its sales by volume decline, Coca-Cola is making up for it by charging more per ounce for the mini-cans & bottles.
Fruit Tart Example Added Sugar Question A formulation for a fruit tart filling includes 100 ml concentrated Grape Juice. How much Total Sugar and Added Sugar will be declared? Known 36g sugar per 60mL conc. 60g sugar per 100mL conc. 1 part conc. and 3 parts water reconstitutes to 100% juice 100mL Juice 60g sugar 100mL conc. 1mL conc. 4mL Juice = 15g X sugar in 100mL 1 Juice 60g sugar conc 15g sugar Juice = 45g X Added Sugar in 100mL concentrate Answer Total Sugars: 60g Added Sugars: 45g
Case Study Toaster Pastries Assess Impact 800 Calories 64g Total Sugar 56 g Added Sugar 112% Added Sugar
Reformulate... Added Sugar Ingredients: Enriched Wheat Flour [Wheat Flour, Niacin, Reduced Iron, Thiamin Mononitrate (Vitamin B1), Riboflavin (Vitamin B2), Folic Acid], Corn Syrup, Sugar, High Fructose Corn Syrup, Palm and/or Canola Oil, Fruit From Concentrate (White Grapes, Strawberry), Glycerine, Modified Corn Starch, Whey Permeate, Precooked Yellow Corn Meal, Salt, Leavening (Sodium Aluminum Phosphate, Baking Soda), Color Added (Includes Red 40, Blue 1), Citric Acid, Malic Acid, Natural and Artificial Flavor, Potassium Sorbate (a Preservative), Gelatin, Yellow Corn Flour, Modified Soy Protein, Vitamin A Palmate, Reduced Iron, Niacinamide, Pyridoxine Hydrochloride (Vitamin B6), Riboflavin (Vitamin B2), Thiamin Mononitrate (Vitamin B1). Reformulate Corn Syrup Sugar High Fructose Corn Syrup Fruit From Concentrate Honey Fruit Puree Stevia 4 count, 52 g
Reformulate... Added Sugar Reformulate Corn Syrup Sugar High Fructose Corn Syrup Fruit From Concentrate 4 count, 52 g => Honey => Fruit Puree => Stevia Honey Fruit Puree Stevia
Case Study Cake Bites: - 8oz package
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Case Study
Case Study Re-package 6oz bag Re-package 13oz bag Re-formulate 13oz bag
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