Last verified 17 Sep 2026 · Sources
“Sugar free” requires less than 0.5 g of sugars per Reference Amount Customarily Consumed (RACC) and per labeled serving (21 CFR 101.60(c)(1)(i)). There’s no reference food to compare against, and no 50 g fallback test the way “low sodium” or “low fat” get one. The trap you’re most likely to hit isn’t the number itself; it’s the second half of the rule you might not expect: a sugar-free claim also requires no sugar-containing ingredient (unless it’s asterisked as trivial) and a mandatory calorie-related statement on the label every time the claim appears.
| Quick facts | Sugar free |
|---|---|
| Regulation | 21 CFR 101.60(c)(1) |
| Threshold | <0.5 g sugars per RACC and per labeled serving; no sugar-source ingredient unless trivial |
| Claim type | absolute |
| Reference food needed | No |
| Disclosure statement | Yes. Must be labeled 'low calorie'/'reduced calorie' or bear 'not a reduced calorie food', 'not a low calorie food', or 'not for weight control' |
| Wordings FDA allows | Sugar free, Free of sugar, No sugar, Zero sugar, Without sugar, Sugarless, Trivial/negligible/dietarily insignificant source of sugar |
What the rule says
21 CFR 101.60(c)(1) sets three conditions, and your product has to clear all three to use “sugar free,” “free of sugar,” “no sugar,” “zero sugar,” “without sugar,” “sugarless,” or “trivial/negligible/dietarily insignificant source of sugar”:
(c)(1)(i): “The food contains less than 0.5 g of sugars, as defined in § 101.9(c)(6)(ii), 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 sugars per labeled serving.” “Sugars” is total sugars (101.9(c)(6)(ii) defines it as “the sum of all free mono- and disaccharides (such as glucose, fructose, lactose, and sucrose)”), not added sugars specifically.
(c)(1)(ii): “The food contains no ingredient that is a sugar or that is generally understood by consumers to contain sugars 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 sugar,’ ‘adds a negligible amount of sugar,’ or ‘adds a dietarily insignificant amount of sugar.’”
(c)(1)(iii): the food must either be labeled “low calorie” or “reduced calorie” (or carry a special-dietary-usefulness claim cross-referenced in 101.60(b)(2)–(b)(5)), or the sugar-free claim must be “immediately accompanied, each time it is used, by either the statement ‘not a reduced calorie food,’ ‘not a low calorie food,’ or ‘not for weight control.’” This keeps a shopper from reading “sugar free” as “diet food” when it isn’t.
Where a food is naturally free of sugar without reformulation (say, plain club soda), 101.13(e)(2) requires the claim to make clear the whole category is this way, not that your brand did something special: “clearly refer to all foods of that type and not merely to the particular brand to which the labeling attaches (e.g., ‘corn oil, a sodium-free food’).” The same logic applies here.
The numbers
- Threshold: under 0.5 g sugars, evaluated per RACC and per labeled serving. Unlike “low” claims, there is no per-50 g fallback for small-RACC foods; that test belongs to “low” claims (low sodium, low calorie), not “free” claims.
- Rounding interplay (21 CFR 101.9(c)(6)(ii)): the panel may show sugars under 0.5 g per serving as “0 g,” but the claim is checked against the actual unrounded value on both bases, not the rounded panel number. If your labeled serving is smaller than the RACC, 0.4 g per serving prints as “0 g Sugars” while the RACC amount can be 0.6 g, which fails the threshold because 0.6 is not less than 0.5.
- Sugar alcohols: “sugars” under 101.9(c)(6)(ii) covers only mono- and disaccharides, so sugar alcohols (sorbitol, xylitol, erythritol, maltitol) don’t count against the 0.5 g threshold. But 101.9(c)(6)(iv) requires their declaration once triggered: “A statement of the number of grams of sugar alcohols in a serving may be declared voluntarily on the label, except that 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.” A sugar-free claim is a total-sugars claim, so if your product contains sugar alcohols, the label must then declare them.
On the label
A sugar-free jerky (/product-labels/jerky/) is a realistic test case, since most commercial marinades lean on brown sugar, honey, or molasses. To earn “sugar free”: swap the sweetener for one that doesn’t read as sugar (or asterisk it as trivial), keep total sugars under 0.5 g per RACC and per labeled serving on the real analysis, and add the required statement. Most jerky isn’t a diet food, so “not for weight control” next to the claim is usually the fastest path, since jerky’s fat and sodium content won’t clear “low calorie” anyway.
Mistakes we see
- Dropping the calorie-status statement. It’s easy to get the sugar number right and forget 101.60(c)(1)(iii) entirely, so no calorie-status wording appears near the claim at all.
- Trusting the rounded panel value. “It says 0 g Sugars, so we’re sugar free” skips the actual unrounded number the claim depends on.
- Missing the sugar alcohol declaration. A sugar-free product sweetened with a sugar alcohol still needs the Sugar Alcohol line on the panel per 101.9(c)(6)(iv) once the claim triggers it.
- Voiding a labeling exemption. 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)) loses it the moment any nutrition claim, including “sugar free,” appears.
- Skipping the “naturally sugar-free” framing. Claiming “sugar free” on a food that was never going to have sugar, without the category-level phrasing 101.13(e)(2) calls for, can read as implying special processing that didn’t happen.
Related claims
See /claims/reduced-sugar/, /claims/no-added-sugar/, /claims/calorie-free/, and /claims/low-calorie/ for the claims sugar-free interacts with most directly, 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 numbers against every basis the rule names (per RACC and per labeled serving) and tells you exactly which claims, and which exact wordings, your product qualifies for.
A “Sugar Free” claim that goes to print with its calorie statement already beside it is one less thing to fix after the first run. 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 reduced sugar.
Sugar free claim FAQ
Can a naturally sugar-free food say "sugar free" without qualification?
It can say 'sugar free,' but 21 CFR 101.13(e)(2) requires the claim to make clear the whole food category is this way, not just this brand (for example 'club soda, a sugar-free food'), when the food is inherently free of the nutrient and hasn't been specially processed.
Does "sugar free" limit sugar alcohols?
No. 101.60(c)(1) only limits sugars as defined in 101.9(c)(6)(ii) (free mono- and disaccharides). A product can be sugar free and still contain sugar alcohols like erythritol or maltitol, but the sugar alcohol grams must then be declared on the Nutrition Facts panel per 101.9(c)(6)(iv).
Does "sugar free" mean the food is low in calories?
Not automatically. That's exactly why the rule requires the extra statement: either the food already qualifies as 'low calorie' or 'reduced calorie,' or the label must say 'not a reduced calorie food,' 'not a low calorie food,' or 'not for weight control' every time the sugar-free claim appears (21 CFR 101.60(c)(1)(iii)).
What sugar level actually rounds to "0 g" on the panel but still fails the claim?
21 CFR 101.9(c)(6)(ii) lets a serving with less than 0.5 g of sugars show '0 g Sugars' on the panel, but the claim is evaluated on the unrounded value, per RACC and per labeled serving. If your labeled serving is smaller than the RACC, your panel can show '0 g' at 0.4 g per serving while the RACC amount is 0.6 g, and the product still doesn't qualify for 'sugar free,' which requires under 0.5 g on both bases.
Can a dietary supplement use "sugar free"?
The claim itself works the same way, but watch the cross-reference in 101.60(c)(1)(iii): a supplement that would meet the 'low calorie' definition in paragraph (b)(2) but is barred from using that specific claim by 101.13(b)(5) and 101.60(a)(4) still needs the 'not a reduced calorie food' style statement instead. Whether a specific supplement format triggers this cross-reference is a question for a labeling attorney.
Related claims
Reduced sugar, No added sugar, Calorie free, Low calorie. See the full all label claims.