Last verified 17 Sep 2026 · Sources
“No added sugar” (and “without added sugar,” “no sugar added”) isn’t a gram threshold like “sugar free”. It’s a process-and-context test under 21 CFR 101.60(c)(2). It requires no sugar or sugar-functioning ingredient added during processing or packaging, no sugar-source ingredient like jam or concentrated fruit juice, no enzymatic method used to raise the sugars content, that the food it resembles normally contains added sugar, and (the condition you’re most likely to miss) a label statement that the product isn’t “low calorie” or “calorie reduced” (unless it independently qualifies), pointing shoppers to the nutrition panel.
| Quick facts | No added sugar |
|---|---|
| Regulation | 21 CFR 101.60(c)(2) |
| Threshold | No sugar or sugar-source ingredient added during processing; not a gram cutoff |
| Claim type | implied |
| Reference food needed | No |
| Disclosure statement | Yes. Must state the food is not 'low calorie'/'calorie reduced' (unless it independently qualifies) and direct consumers to the nutrition panel |
| Wordings FDA allows | No added sugar, Without added sugar, No sugar added |
What the rule says
21 CFR 101.60(c)(2) permits “no added sugar,” “without added sugar,” or “no sugar added” only if all five conditions are met:
(c)(2)(i): “No amount of sugars, as defined in § 101.9(c)(6)(ii), or any other ingredient that contains sugars that functionally substitute for added sugars is added during processing or packaging.”
(c)(2)(ii): “The product does not contain an ingredient containing added sugars such as jam, jelly, or concentrated fruit juice.”
(c)(2)(iii): “The sugars content has not been increased above the amount present in the ingredients by some means such as the use of enzymes, except where the intended functional effect of the process is not to increase the sugars content of a food, and a functionally insignificant increase in sugars results.”
(c)(2)(iv): “The food that it resembles and for which it substitutes normally contains added sugars.” You can say a juice has “no added sugar” because juice in general is often sweetened, but the claim makes less sense on a food nobody sweetens in the first place.
(c)(2)(v): “The product bears a statement that the food is not ‘low calorie’ or ‘calorie reduced’ (unless the food meets the requirements for a ‘low’ or ‘reduced calorie’ food) and that directs consumers’ attention to the nutrition panel for further information on sugar and calorie content.” This is the condition most often left off. A shopper reading “no added sugar” can otherwise assume “diet food,” and this line corrects that when it isn’t true.
Note the difference from “sugar free”: that claim (101.60(c)(1)) is a quantitative test against 0.5 g of total sugars. “No added sugar” is qualitative: it’s about what was done during processing, not a gram figure a lab reports.
The numbers
- No numeric threshold. Unlike “sugar free” and “reduced sugar,” there’s no per-RACC or per-labeled-serving gram cutoff. If your product is naturally sugary, it can still say “no added sugar” as long as none of that sugar was added during processing.
- Interplay with the Added Sugars line: the mandatory Added Sugars line on the Nutrition Facts panel (21 CFR 101.9) reports grams of sugars added during processing. A truthful “no added sugar” claim should correspond to an Added Sugars line reading 0 g; a nonzero figure there puts the claim and the panel in direct conflict.
- Sugar alcohols: because “sugars” under 101.9(c)(6)(ii) covers free mono- and disaccharides, not sugar alcohols, a product sweetened with a sugar alcohol can potentially clear this claim on the sugar side. But any sugar-content claim while sugar alcohols are present triggers the mandatory Sugar Alcohol declaration under 101.9(c)(6)(iv): “when a claim is made on the label or in labeling about sugar alcohol or total sugars, or added sugars when sugar alcohols are present in the food, sugar alcohol content shall be declared.” FDA’s guidance on added sugars does not address this claim by name; the regulation text governs.
- Rounding interplay (101.9(c)): rounding the sugars figure on the panel doesn’t itself affect whether “no added sugar” is true. What matters is whether a sugar-source ingredient was actually added, a formulation fact, not a rounding question.
On the label
A juice-type beverage (/product-labels/juice/) fits this claim well, since sweetened juice is common in the category (satisfying (c)(2)(iv)), while an unsweetened version has no processing-stage sugar addition. To use “No Sugar Added”: confirm no sweetener, concentrate, or syrup was added (c)(2)(i)–(iii)), verify the Added Sugars line reads 0 g, and add a statement such as “Not a low calorie food. See nutrition information for sugar and calorie content” near the claim to satisfy (c)(2)(v), unless the product independently qualifies as low or reduced calorie.
Mistakes we see
- Leaving off the (c)(2)(v) statement. The formulation is genuinely free of added sugar, but nothing on the label addresses calorie status or points to the nutrition panel.
- Using a sugar-containing ingredient as a “natural” workaround. Concentrated fruit juice, honey, or jam added to sweeten a product disqualifies the claim under (c)(2)(ii), even when marketed as a “natural” sweetener.
- Making the claim on a food nobody sweetens. A product whose category doesn’t normally carry added sugar doesn’t meet the (c)(2)(iv) condition.
- Missing the sugar alcohol declaration. Sweetening with a sugar alcohol while making this claim triggers the mandatory Sugar Alcohol line under 101.9(c)(6)(iv).
- Voiding a small-package exemption. “No added sugar” on a package that would otherwise qualify for the small-package exemption (21 CFR 101.9(j)(13)(i)) or low-volume exemption (101.9(j)(18)) removes that exemption.
Related claims
See /claims/sugar-free/, /claims/reduced-sugar/, /claims/calorie-free/, and /claims/low-calorie/, plus /labeling-rules/nutrient-content-claims/ and /labeling-rules/rounding-rules/.
Check your label
The NutriLabels builder’s claims check looks at your formulation and your Added Sugars figure together and tells you which claims, and which exact wordings, your product qualifies for, including whether the required calorie-status statement applies to you.
When your “No Sugar Added” claim, your 0 g Added Sugars line, and the calorie statement all agree, a shopper reading your label gets one consistent story. Enter your recipe, then see your label: your calories, 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, ready to print. Start your label or compare sugar free.
No added sugar claim FAQ
Is "no added sugar" evaluated against a gram threshold like "sugar free"?
No. 101.60(c)(2) is a process-and-ingredient test (no sugar or sugar-functioning ingredient added during processing, no sugar-containing ingredient like jam or concentrated fruit juice, and no enzymatic or other means used to raise the sugars content), not a numeric cutoff the way 'sugar free' (under 0.5 g) or 'low sugar' would be.
Can a product be "no added sugar" and still show sugars on the Nutrition Facts panel?
Yes. A naturally sugary food (say, a fruit product) can have no added sugar and still show a nonzero Total Sugars line, because the claim is about what was added during processing, not the total amount present. The Added Sugars line specifically should read 0 g when this claim is true, since that line reports only sugars added during processing.
Does a "no added sugar" product need to say anything about calories?
Yes, unless it independently qualifies as low or reduced calorie. 21 CFR 101.60(c)(2)(v) requires a statement that the food is not 'low calorie' or 'calorie reduced' (unless it meets those definitions) and that directs the shopper to the nutrition panel for calorie and sugar information.
Does the claim work if sugar alcohols are used as the sweetener?
The claim itself is about sugars as defined in 101.9(c)(6)(ii), which sugar alcohols aren't part of, so using a sugar alcohol as sweetener doesn't itself violate 'no added sugar.' But once a sugar-content claim like this one is made and sugar alcohols are present, 101.9(c)(6)(iv) makes the Sugar Alcohol declaration on the panel mandatory rather than voluntary. FDA's guidance on added sugars does not address this claim by name; the regulation text governs.
Can "no added sugar" appear on a food that normally never has added sugar?
21 CFR 101.60(c)(2)(iv) requires that 'the food that it resembles and for which it substitutes normally contains added sugars.' Plain water, for instance, doesn't normally contain added sugar in the category sense, so 'no added sugar' on plain water would not meet this condition the way it does on, say, a juice or applesauce that competitors typically sweeten.
Related claims
Sugar free, Reduced sugar, Calorie free, Low calorie. See the full all label claims.