Last verified 17 Sep 2026 · Sources
“High,” “rich in,” and “excellent source of” are the same claim under FDA rules and all require 20 percent or more of the Reference Daily Intake (RDI) or Daily Reference Value (DRV) per Reference Amount Customarily Consumed (RACC). No reference food is needed and there’s no per-labeled-serving basis, just that one percentage against your RACC (21 CFR 101.54(b)(1)). “High potency” is a related but stricter claim under 101.54(f) that needs 100% of the RDI. The trap you’re most likely to hit: running the percentage against your labeled serving size instead of the FDA’s RACC for your food category, which can produce a passing number that doesn’t actually qualify.
| Quick facts | High in / Rich in / Excellent source of [nutrient] |
|---|---|
| Regulation | 21 CFR 101.54(b) |
| Threshold | ≥20% of the RDI or DRV per RACC ("high potency" ≥100%) |
| Claim type | absolute |
| Reference food needed | No |
| Disclosure statement | Yes. Fiber claims need the low-fat fat disclosure (101.54(d)) unless the food is already low fat; any claim on a food over 13 g fat, 4 g sat fat, 60 mg cholesterol or 480 mg sodium per RACC needs the 101.13(h) disclosure statement |
| Wordings FDA allows | High, High in, Rich in, Excellent source of; High potency (single vitamin/mineral ≥100% RDI, or multi-ingredient product ≥100% RDI for at least two-thirds of the vitamins/minerals present at 2%+ RDI) |
What the rule says
21 CFR 101.54(b)(1): “The terms ‘high,’ ‘rich in,’ or ‘excellent source of’ may be used on the label and in the labeling of foods… provided that the food contains 20 percent or more of the RDI or the DRV per reference amount customarily consumed” (21 CFR 101.54). Any of the three phrasings is legally identical.
For meal products and main dish products, 101.54(b)(2) extends the claim: the product qualifies if it “contains a food that meets the definition of ‘high’” for the nutrient and “the label or labeling clearly identifies the food that is the subject of the claim”, so a soup can say “excellent source of vitamin A from the carrots” pointing at the qualifying ingredient, rather than claiming the whole dish independently clears 20% (21 CFR 101.54).
“High potency,” 101.54(f)(1)(i): for a single vitamin or mineral, “the term ‘high potency’ may be used on the label or in the labeling of foods to describe individual vitamins or minerals that are present at 100 percent or more of the RDI per reference amount customarily consumed.” For multi-ingredient products, the same section extends the term to a product containing “100 percent or more of the RDI for at least two-thirds of the vitamins and minerals that are listed in § 101.9(c)(8)(iv) and that are present in the product at 2 percent or more of the RDI” (21 CFR 101.54).
The same fiber and protein add-on rules from 101.54(c) apply here too: a fiber claim on a food that isn’t low fat under 101.62(b)(2) needs the 101.54(d) fat disclosure, and a protein claim at any percentage requires the corrected PDCAAS figure under 101.9(c)(7), not crude protein (21 CFR 101.9).
The numbers
| Claim | Threshold | Basis |
|---|---|---|
| Good source / Contains / Provides | 10–19% of RDI or DRV | Per RACC (see good-source) |
| High / Rich in / Excellent source of | 20% or more of RDI or DRV | Per RACC |
| High potency (single nutrient) | 100% or more of RDI | Per RACC |
| High potency (multi-ingredient product) | 100%+ RDI for ≥2/3 of the vitamins/minerals present at ≥2% RDI | Per RACC |
There’s no small-RACC per-50-g variant here; that mechanism is specific to the “low” and “free” claims in 101.60–101.62. Rounding interplay works the same way as for good source: the %DV printed on the Nutrition Facts panel is rounded per 101.9(c) for display, but claim eligibility runs on the unrounded, as-analyzed nutrient amount, so a food that rounds to 20% on the panel but tests at 19.4% unrounded doesn’t clear the bar.
On the label
A cup of orange juice with a RACC of 8 fl oz (21 CFR 101.12) delivering 72 mg of vitamin C against a 90 mg RDI comes to 80%, well over the 20% line, so “Excellent source of vitamin C” is available, and it’s nowhere near the 100% needed for “high potency” on that nutrient alone. Build the /product-labels/juice/ panel and both the RDI percentage and whether the product also clears “high potency” come out of the same USDA FoodData Central plus supplier spec-sheet analysis.
Mistakes we see
- Checking the percentage against the labeled serving size instead of the RACC. 101.54(b) and (c) are both explicitly “per reference amount customarily consumed”. If your labeled serving is larger than the RACC, you can undercount your qualifying percentage, or overcount it if your serving is smaller.
- Confusing “high” with “high potency.” They sound similar but sit at 20% and 100% respectively; using “high potency” language for a 20%-level nutrient overstates the claim.
- Skipping the fiber fat disclosure at the higher threshold too. The 101.54(d) disclosure requirement isn’t specific to “good source”; it applies to any fiber-level claim, including “excellent source of fiber.”
- Claiming “excellent source of protein” without a PDCAAS value. Same rule as good source: 101.9(c)(7) requires the corrected score, and a crude-protein recipe calculation isn’t a substitute.
- Voiding a small-package or exemption format. A high/excellent-source claim is a nutrition claim under 101.9(j)(4) and (j)(13), so it removes eligibility for the reduced-format and no-panel options those exemptions offer.
Related claims
See Good source / Contains / Provides for the 10–19% version of this same test, More / Fortified for the comparative version against a reference food, and Healthy for the separate implied claim built on food groups rather than a single-nutrient percentage. General background is at /labeling-rules/nutrient-content-claims/ and /labeling-rules/rounding-rules/.
Check your label
The NutriLabels builder’s claims check runs your product’s analyzed nutrient values against the RDI and DRV tables at every threshold on this page (good source, excellent source, and high potency) per RACC, and tells you which exact wording your product qualifies to print.
Running the percentage against the RACC first means the “excellent source” on your front panel matches the number behind it. Enter your recipe, then see your label: free with no card required, you see your calories, the claims you qualify for, your allergen line and the nutrient to watch, and every other value and %DV stays hidden until you unlock it. $29 unlocks every other nutrient value and %DV, every FDA format your product qualifies for, and the ingredient statement and allergen declaration, ready to print. Start your label or compare the 10–19% good source claim.
High in / Rich in / Excellent source of [nutrient] claim FAQ
What's the difference between "high," "rich in," and "excellent source of"?
Nothing legally. 21 CFR 101.54(b)(1) lists all three as interchangeable wordings for the same 20%-or-more-of-RDI-or-DRV threshold per RACC (21 CFR 101.54).
Is "high potency" the same claim at a higher number?
It's a related but separate claim under 101.54(f). For a single vitamin or mineral it requires 100% or more of the RDI per RACC. For a multi-ingredient product, it requires 100% or more of the RDI for at least two-thirds of the vitamins and minerals that are present at 2% or more of the RDI (21 CFR 101.54).
Can a frozen meal say "excellent source of" a nutrient in one ingredient?
Yes, under 101.54(b)(2), if a component of the meal or main dish product independently meets the 20% threshold and the label clearly identifies which food is the subject of the claim (21 CFR 101.54).
Does an excellent source of protein claim need PDCAAS too?
Yes. 21 CFR 101.9(c)(7) requires the protein digestibility-corrected amino acid score for any protein content claim, at any threshold (good source or excellent source), not the crude protein figure from a recipe rollup (21 CFR 101.9).
Does this claim need a reference food or comparative statement?
No. It's an absolute claim tested against a fixed RDI/DRV percentage, so 21 CFR 101.13(j)'s reference-food rules for relative claims (more, less, reduced, light) don't apply here (21 CFR 101.13).
Related claims
Good source of [nutrient], More / Added / Extra / Fortified / Enriched [nutrient], Healthy, Low fat. See the full all label claims.