Last verified 17 Sep 2026 · Sources
Your product can carry “fat free,” “zero fat,” or “nonfat” only if it contains less than 0.5 gram of fat per Reference Amount Customarily Consumed (RACC) and per labeled serving; for a meal or main dish product, less than 0.5 g per labeled serving alone (21 CFR 101.62(b)(1)(i)). There’s no reference food to compare against; it’s a flat number. The trap you’re most likely to hit isn’t the threshold itself. It’s the added-fat rule: even if your product is under 0.5 g, it can’t claim fat free if it contains an added ingredient that’s a fat or generally understood to contain fat, unless that ingredient is asterisked to a disclosure statement (below). And “100% fat free” is a different, stricter claim than plain “fat free”, and conflating the two is the second-most-common mistake.
| Quick facts | Fat free |
|---|---|
| Regulation | 21 CFR 101.62(b)(1) |
| Threshold | <0.5 g fat per RACC and per labeled serving (meal/main dish: <0.5 g per labeled serving) |
| Claim type | absolute |
| Reference food needed | No |
| Disclosure statement | Not applicable to fat-free itself, but any other nutrient content claim on the same label triggers disclosure if fat >13 g, sat fat >4 g, cholesterol >60 mg or sodium >480 mg per RACC (21 CFR 101.13(h)(1)) |
| Wordings FDA allows | Free of fat, No fat, Zero fat, Without fat, Nonfat, Negligible/dietarily insignificant source of fat |
What the rule says
21 CFR 101.62(b)(1)(i) sets the number: “The food contains less than 0.5 gram (g) of fat per reference amount customarily consumed and per labeled serving or, in the case of a meal product or main dish product, less than 0.5 g of fat per labeled serving.” Allowed synonyms in the same paragraph include “free of fat,” “no fat,” “zero fat,” “without fat,” “negligible”/”dietarily insignificant source of fat,” and “nonfat.”
The added-fat condition, 21 CFR 101.62(b)(1)(ii), is read on eCFR as: “The food contains no added ingredient that is a fat or is generally understood by consumers to contain fat unless the listing of the ingredient in the ingredient statement is followed by an asterisk that refers to the statement below the list of ingredients, which states ‘adds a trivial amount of fat,’ ‘adds a negligible amount of fat,’ or ‘adds a dietarily insignificant amount of fat.’” So a small amount of added oil or a fat-containing flavoring doesn’t automatically kill the claim, but it does require that asterisked disclosure on the ingredient list.
If your food is inherently fat free without reformulation (a plain vinegar or a fruit leather with no added fat), 21 CFR 101.13(e)(2) requires the claim to indicate the food is fat free as a category, not that your brand specifically changed anything (the rule’s own parallel example: “corn oil, a sodium-free food”).
“100 percent fat free” is a separate, stricter claim under 101.62(b)(6): confirmed on eCFR, it requires the food to (i) meet the fat-free criteria in (b)(1), (ii) contain less than 0.5 g fat per 100 g, and (iii) contain no added fat ingredient at all, with no small-serving exception. A food that squeaks under 0.5 g at a small RACC but is fattier per 100 g can fail “100% fat free” while still legitimately saying plain “fat free.” A related claim in the same paragraph, “__% fat free,” requires the food to first meet the “low fat” definition in 101.62(b)(2) or (b)(3). It’s not available to a food that only clears the fat-free bar, and the declared percentage and the words “fat free” must appear in uniform type size.
The numbers
Fat free is checked on two bases only, per RACC and per labeled serving, with no per-50-g variant, unlike “low fat,” which adds that test for small-RACC foods.
Rounding matters here because the threshold (0.5 g) sits exactly on a rounding boundary. Under 21 CFR 101.9(c)(2), fat “shall be expressed to the nearest 0.5 gram increment below 5 grams… If the serving contains less than 0.5 gram, the content shall be expressed as zero.” A panel showing “0 g Total Fat” confirms the unrounded value is under 0.5 g, but the claim always runs on that underlying analyzed number, not on a printed rounded figure you’re eyeballing from someone else’s label.
“Reduced fat,” “less fat,” and “light” use an entirely different, relative test with a reference food under 101.13(j). See /claims/reduced-fat/ rather than treating them as stricter versions of fat free.
On the label
Take a jar of dill pickle spears: analyzed fat is about 0.09 g per 30 g serving, with no added fat ingredient in the brine. That clears the fat-free threshold on both bases, and because pickles are inherently fat free rather than reformulated, the claim should read as “Fat Free” without implying this brand specifically removed fat. Per 101.13(e)(2), use wording that credits pickles generally as a fat-free food. See a full build at /product-labels/pickles/.
Mistakes we see
- Treating “fat free” and “100% fat free” as interchangeable. The 100% version adds the per-100-g check and drops any tolerance for added fat.
- Adding a fat ingredient without the asterisk. A small amount of added oil still needs the “adds a trivial amount of fat” disclosure under 101.62(b)(1)(ii), even if the total stays under 0.5 g.
- Applying the per-50-g small-package test. That test belongs to “low fat,” not “fat free.”
- Printing the claim on a label relying on a “no claims” exemption. The small-package, retail, and low-volume exemptions in 21 CFR 101.9(j), including (j)(13)(i) and (j)(18), require no nutrient content claims; “fat free” voids that exemption and triggers the full panel.
- Skipping the “naturally fat free” language on an unprocessed product. Implying your brand achieved something every product in the category already has is a 101.13(e)(2) problem.
Related claims
See /claims/low-fat/ for the ≤3 g threshold, /claims/reduced-fat/ for the comparative version, /claims/saturated-fat-free/ and /claims/cholesterol-free/ for the related fat-family claims, plus the general rules at /labeling-rules/nutrient-content-claims/ and /labeling-rules/rounding-rules/.
Check your label
The NutriLabels builder’s claims check runs your product’s fat number against this threshold on every basis the rule names (per RACC and per labeled serving) and tells you exactly which wording (“fat free,” “nonfat,” or “100% fat free”) your product qualifies for.
Knowing which of the three wordings your numbers support lets you print the strongest claim you can stand behind. Enter your recipe, then see your label: its shape and calorie count, the claims you qualify for and your allergen line are free, no card required, and every other value and %DV stays hidden until you unlock it. $29 unlocks every other nutrient value and %DV, the claims check, every FDA format your product qualifies for, and the ingredient statement and allergen declaration; or send us the recipe and we build it (done-for-you, $249, within 5 business days). Start your label or compare the other nutrient content claims.
Fat free claim FAQ
Can I say 'nonfat' instead of 'fat free'?
Yes. 21 CFR 101.62(b)(1) lists 'nonfat' and 'fat free' as the same claim with the same threshold.
Does '0 g Total Fat' on my panel mean I can say fat free?
Not automatically. The panel rounds fat under 0.5 g down to zero, but the claim is judged on the unrounded lab or database value, so you still need to confirm it's actually below 0.5 g.
Can a naturally fat-free food like plain rice cakes say 'fat free'?
Yes, but 21 CFR 101.13(e)(2) says the statement has to make clear the whole food category is inherently fat free, not imply your brand specifically removed the fat.
What's different about '100% fat free'?
It's a separate, stricter claim under 101.62(b)(6): the food must meet the fat-free test, contain less than 0.5 g fat per 100 g, and have no added fat ingredient at all.
Do I need a reference food to say fat free?
No. Fat free is an absolute claim: it's a fixed threshold, not a comparison to another product.
Does the fat-free threshold change for small packages?
No. Unlike 'low fat,' the fat-free claim has no per-50 g version. It's assessed only per RACC and per labeled serving, regardless of package or RACC size.
Related claims
Low fat, Reduced fat, Saturated fat free, Cholesterol free. See the full all label claims.