Last verified 17 Sep 2026 · Sources
“Low calorie” means your product provides 40 calories or less per Reference Amount Customarily Consumed (RACC) (21 CFR 101.60(b)(2)(i)(A)). And if your RACC is 30 g or less, or 2 tablespoons or less, the rule also requires 40 calories or less per 50 g of food (same paragraph, (B)), with sugar substitutes excused from that second leg. It’s an absolute claim, so no reference food is needed. The trap: with a small RACC (a spice blend, a hot sauce, a candy), it’s easy to check only the per-RACC number, forget the per-50-g leg applies to your product specifically, and print a claim your product doesn’t actually clear once scaled to 50 g.
| Quick facts | Low calorie |
|---|---|
| Regulation | 21 CFR 101.60(b)(2) |
| Threshold | ≤40 cal/RACC (and /50 g if RACC ≤30 g/2 tbsp, except sugar subs); ≤120 cal/100 g meal/main |
| Claim type | absolute |
| Reference food needed | No |
| Disclosure statement | Not applicable |
| Wordings FDA allows | Low calorie, Few calories, Contains a small amount of calories, Low source of calories, Low in calories |
What the rule says
21 CFR 101.60(b)(2)(i) reads: “(A) The food has a reference amount customarily consumed greater than 30 grams (g) or greater than 2 tablespoons and does not provide more than 40 calories per reference amount customarily consumed; or (B) The food has a reference amount customarily consumed of 30 g or less or 2 tablespoons or less and does not provide more than 40 calories per reference amount customarily consumed and, except for sugar substitutes, per 50 g.”
FDA allows any of these wordings for the same claim: “low calorie,” “few calories,” “contains a small amount of calories,” “low source of calories,” or “low in calories.”
If your food is inherently low calorie without reformulation, 21 CFR 101.60(b)(2)(ii) requires the label say so at the category level, not the brand level: “it is labeled to clearly refer to all foods of its type and not merely to the particular brand to which the label attaches (e.g., ‘celery, a low calorie food’).”
The numbers
| RACC size | Basis | Threshold |
|---|---|---|
| RACC > 30 g or > 2 tbsp | Per RACC | ≤40 calories |
| RACC ≤ 30 g or ≤ 2 tbsp | Per RACC and per 50 g (except sugar substitutes) | ≤40 calories on both |
| Meal or main dish product | Per 100 g | ≤120 calories (21 CFR 101.60(b)(3)(i)) |
The meal/main-dish figure isn’t the 40-calorie test scaled up. It’s its own threshold, written separately in 101.60(b)(3)(i): “The product contains 120 calories or less per 100 g.” A frozen entrée and a bag of chips are evaluated on entirely different numbers, even though both might carry a “low calorie” claim.
Rounding under 21 CFR 101.9(c)(1) governs what prints on the panel, but the claim itself is checked against your unrounded analytical or database number. If your product analyzes to 40.4 calories per RACC, it does not qualify: “40 calories or less” means the real number, not a rounded-down label figure.
On the label
Take a bag of granola with a RACC of 55 g (over the 30 g/2 tbsp small-RACC line per 21 CFR 101.12’s table). If your recipe analyzes to 38 calories per 55 g serving, you clear the ≤40-calorie-per-RACC test with no per-50-g check required, since your RACC is over the small-RACC threshold. You could print “Low Calorie” on the front panel. See how RACC and serving size interact for this category on our granola label guide.
Now take a hot sauce with a RACC of 1 teaspoon (5 g), under the 30 g/2 tbsp line. Say your formula comes to 8 calories per 5 g RACC. That clears the per-RACC leg easily, but scaled up, 8 calories per 5 g works out to 80 calories per 50 g, over the ≤40-per-50-g limit. This product cannot claim “low calorie,” because the small-RACC rule exists precisely to stop concentrated, small-serving foods from claiming “low” on serving size alone. See the hot sauce label guide.
Mistakes we see
- Skipping the per-50-g test on a small RACC. If your RACC is 30 g/2 tbsp or less, the per-RACC number alone isn’t enough; the food also has to pass per 50 g (sugar substitutes are the one exception).
- Using the wrong threshold on a meal or main dish product. Frozen entrées, soups, and similar products use 120 calories per 100 g (101.60(b)(3)(i)), not the 40-calorie RACC test built for standalone foods.
- Trusting the rounded panel number instead of the underlying analysis. 21 CFR 101.9(c)(1) rounding can make a borderline product look compliant on the printed label when the real, unrounded value fails the threshold.
- Making the claim on a product using a small-package or 101.9(j)(4) exemption. Both exemptions require the label carry no nutrition claims; adding “low calorie” ends the exemption and triggers full Nutrition Facts panel requirements.
Related claims
See calorie free, reduced calorie, light, and good source, plus nutrient content claims and rounding rules.
Check your label
Our builder’s claims check evaluates your product’s numbers against this threshold on every basis the rule names (per RACC, per labeled serving, and per 50 g where it applies) and tells you which calorie claims, and which exact wordings, your product qualifies for.
Running the per-50-g leg before you print means a small-serving product’s “Low Calorie” claim holds up at any scale. 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, 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 see the other nutrient content claims.
Low calorie claim FAQ
What's the low calorie threshold for a normal-size RACC?
40 calories or less per RACC, under 21 CFR 101.60(b)(2)(i)(A), when your RACC is greater than 30 g or greater than 2 tablespoons.
What changes if my RACC is small, like a spice or a hard candy?
If your RACC is 30 g or less, or 2 tablespoons or less, the food has to come in at 40 calories or less per RACC AND per 50 g, per 21 CFR 101.60(b)(2)(i)(B), except sugar substitutes, which are excused from the per-50-g leg.
Is the threshold different for a frozen dinner or soup?
Yes. Meal and main dish products use 120 calories or less per 100 g under 21 CFR 101.60(b)(3)(i), not the 40-calorie RACC test.
Does 'low calorie' need a reference food or comparative statement?
No. It's an absolute claim under 21 CFR 101.13: a fixed number your product either meets or doesn't, with no comparison food to name.
Related claims
Calorie free, Reduced calorie / Fewer calories, Light / Lite, Good source of [nutrient]. See the full all label claims.