Last verified 17 Sep 2026 · Sources
Your product can be labeled “low fat” if it contains 3 grams of fat or less per Reference Amount Customarily Consumed (RACC). When that RACC is 30 g or less (or 2 tablespoons or less), it must also stay at or under 3 g per 50 g of food (21 CFR 101.62(b)(2)(i)). Meal and main dish products get their own, separate test: 3 g or less per 100 g and no more than 30% of calories from fat (101.62(b)(3)(i)). It’s an absolute claim, so no reference food is needed. The trap you’re most likely to hit: checking the per-RACC number, seeing it’s under 3 g, and stopping, without realizing a small RACC also has to clear the per-50-g bar, which a concentrated, low-serving-size product can fail even when its per-RACC fat looks fine.
| Quick facts | Low fat |
|---|---|
| Regulation | 21 CFR 101.62(b)(2) |
| Threshold | ≤3 g fat/RACC (and /50 g if RACC ≤30 g/2 tbsp); meal/main ≤3 g/100 g, ≤30% cal from fat |
| Claim type | absolute |
| Reference food needed | No |
| Disclosure statement | Not applicable to low fat itself, but any nutrient content claim on the 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 | Low in fat, Contains a small amount of fat, Low source of fat, Little fat |
What the rule says
21 CFR 101.62(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 contain more than [sic: text reads ‘contains’] 3 g or less of fat 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 contains 3 g or less of fat per reference amount customarily consumed and per 50 g of food.” Allowed synonyms in the same paragraph: “low in fat,” “contains a small amount of fat,” “low source of fat,” and “little fat.”
For a meal or main dish product, 101.62(b)(3)(i) substitutes its own basis: “The product contains 3 g or less of total fat per 100 g and not more than 30 percent of calories from fat.” That’s a genuinely different test, not the same 3 g figure applied to a different denominator by coincidence. A soup or frozen entrée is never judged per RACC for this claim.
If your product is inherently low in fat without reformulation (air-popped popcorn is a common example), 21 CFR 101.13(e)(2) requires the claim to indicate that the whole food category is low fat, not that your specific product was engineered to get there: language along the lines of “a low fat food” rather than implying a proprietary reduction.
The numbers
The small-RACC per-50-g test only kicks in at RACC ≤30 g or ≤2 tablespoons. Above that line, the per-RACC number alone decides it. This shape matches low sodium and low calorie, but not “low saturated fat,” which has no 50 g variant, so don’t assume every “low” claim carries the same small-package check.
Rounding interacts with this threshold more than it does with fat-free, because 3 g sits well inside the range where fat rounds to the nearest 0.5 g below 5 g (21 CFR 101.9(c)(2)). A panel that displays “3 g Total Fat” can represent an unrounded value anywhere from about 2.75 g up to 3.24 g, and if the real number is 3.1 g, the claim fails even though the printed panel shows exactly “3 g.” The claim always runs against the underlying analyzed or database value, never the rounded print figure.
For a meal or main dish product, add the 30%-calories-from-fat check on top of the 3 g/100 g figure. A product can pass the gram test and still fail on percent of calories if its total calorie count is unusually low.
On the label
Air-popped popcorn analyzes at about 4.5 g fat per 100 g. At a 30 g serving (about 3½ cups popped, itself at the small-RACC boundary of “30 g or less”), that’s roughly 1.35 g fat per RACC (comfortably under 3 g), and the required per-50-g check comes out to about 2.25 g, also under 3 g. Both bases clear, so “low fat” is available, and because the fat comes entirely from the corn itself with no added oil, the wording should reflect that it’s inherently low fat rather than reformulated, per 101.13(e)(2). See a full build for this category at /product-labels/popcorn/.
Mistakes we see
- Skipping the per-50-g test on a small RACC. A concentrated product can pass per-RACC and still fail per 50 g.
- Using the plain per-RACC test on a meal or main dish. Soups and frozen entrées use the 3 g per 100 g plus 30%-calories-from-fat test in 101.62(b)(3)(i) instead.
- Trusting the rounded panel number at the boundary. A printed “3 g” can hide an unrounded value over the threshold.
- Printing the claim on a label relying on a “no claims” exemption. The exemptions in 21 CFR 101.9(j), including (j)(13)(i) and (j)(18), require no nutrient content claims; adding “low fat” voids them.
- Implying a naturally low-fat product was specially reduced. For an unprocessed food, 101.13(e)(2) requires wording that credits the category, not the brand.
Related claims
See /claims/fat-free/ for the stricter absolute claim, /claims/reduced-fat/ for the comparative version, /claims/low-saturated-fat/ for the related fat-family claim, and /claims/light/ for the claim that also touches fat reduction. General rules: /labeling-rules/nutrient-content-claims/ and /labeling-rules/rounding-rules/.
Check your label
The NutriLabels builder’s claims check evaluates your product’s fat number on every basis the rule names (per RACC, per 50 g where it applies, and per 100 g for meal and main dish products) and tells you which exact wording your product qualifies for.
Checking the unrounded fat number on every basis means the “Low Fat” on your package still holds when someone does the math. 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, the claims check, every FDA format your product qualifies for, and the ingredient statement and allergen declaration, ready to print. Start your label or browse the other nutrient content claims.
Low fat claim FAQ
Does 'low fat' need a per-50 g check?
Only if your RACC is 30 g or less, or 2 tablespoons or less. Above that, the per-RACC test alone applies (21 CFR 101.62(b)(2)(i)).
Is the threshold different for a soup or frozen entrée?
Yes. Meal and main dish products are tested per 100 g (3 g or less) and must also keep fat under 30% of calories, per 101.62(b)(3)(i), not the plain per-RACC test.
Can popcorn or another naturally low-fat food say 'low fat'?
Yes, but 21 CFR 101.13(e)(2) requires the wording to make clear the food is inherently low fat as a category, not that your process lowered it.
If my panel shows '3 g Total Fat,' am I automatically low fat?
Not necessarily. Fat under 5 g rounds to the nearest 0.5 g (101.9(c)(2)), so a printed '3 g' could represent an unrounded value up to 3.24 g, which is over the threshold. The claim runs on the unrounded number.
Do I need a reference food for 'low fat'?
No. Low fat is an absolute claim with a fixed threshold, unlike 'reduced fat,' which requires a comparison food.
What synonyms can I use instead of 'low fat'?
21 CFR 101.62(b)(2) also permits 'low in fat,' 'contains a small amount of fat,' 'low source of fat,' and 'little fat.'
Related claims
Fat free, Reduced fat, Low saturated fat / Reduced saturated fat, Light / Lite. See the full all label claims.