Last verified 17 Sep 2026 · Sources
“More,” “added,” “extra,” “fortified,” and “enriched” are the same relative claim under FDA rules: the food must contain at least 10 percent more of the RDI (for vitamins and minerals) or the DRV (for protein, dietary fiber, or potassium) per Reference Amount Customarily Consumed (RACC) than an appropriate reference food (21 CFR 101.54(e)(1)(i)). Unlike good source or excellent source, this is a relative claim. It needs a reference food, and 21 CFR 101.13(j) requires a comparison statement declaring the reference food’s identity and the percentage difference in immediate proximity to the claim. The trap you’re most likely to hit: adding the nutrient claim without publishing the comparison statement in the required format, which makes an otherwise-qualifying claim non-compliant on its face.
| Quick facts | More / Added / Extra / Fortified / Enriched [nutrient] |
|---|---|
| Regulation | 21 CFR 101.54(e) |
| Threshold | ≥10% more of the RDI/DRV per RACC than the reference food |
| Claim type | relative |
| Reference food needed | Yes |
| Disclosure statement | Not applicable directly, but 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, and fiber claims need the 101.54(d) fat disclosure |
| Wordings FDA allows | More, Added, Extra, Plus, Fortified, Enriched |
What the rule says
21 CFR 101.54(e)(1)(i): “A relative claim using the terms ‘more,’ ‘fortified,’ ‘enriched,’ ‘added,’ ‘extra,’ and ‘plus’ may be used… provided that the food contains at least 10 percent more of the RDI for vitamins or minerals or of the DRV for protein, dietary fiber, or potassium… than an appropriate reference food” (21 CFR 101.54).
The same paragraph, at (e)(1)(iii), sets the required label content: “(A) The identity of the reference food and the percentage (or fraction) that the nutrient is greater relative to the RDI or DRV are declared in immediate proximity to the most prominent such claim; (B) Quantitative information comparing the level of the nutrient in the product per labeled serving with that of the reference food that it replaces… is declared adjacent to the most prominent claim or to the nutrition label” (21 CFR 101.54).
This layers on top of the general relative-claim rule at 101.13(j)(2), which requires the label to state “the identity of the reference food and the percentage (or fraction) of the amount of the nutrient in the reference food by which the nutrient in the labeled food differs (e.g., ’50 percent less fat than (reference food)’),” plus “clear and concise quantitative information comparing the amount of the subject nutrient in the product per labeled serving with that in the reference food” (21 CFR 101.13).
Separately, FDA’s fortification policy at 21 CFR 104.20 sets out when the agency considers adding a nutrient to a food appropriate at all (to correct a demonstrated dietary insufficiency, restore nutrients lost in processing, fortify in proportion to caloric content, or keep a substitute food nutritionally equivalent to what it replaces) and states FDA “does not consider it appropriate to fortify fresh produce; meat, poultry, or fish products; sugars; or snack foods such as candies and carbonated beverages” (21 CFR 104.20). That’s separate from whether a “more” or “fortified” claim is worded correctly. Your product can meet 101.54(e)’s 10% threshold and still raise a 104.20 policy question about the category. Whether 104.20 restricts a claim is a question for a labeling attorney.
The numbers
The threshold is 10 percent or more of the RDI/DRV per RACC than the reference food, with no small-RACC per-50-g variant, since 101.54(e) doesn’t include one the way the calorie/sodium/fat “low” claims do. Worked comparison: a reference bread at 3% DV iron per RACC versus a fortified version at 15% DV iron is a 400% relative increase (well past 10%), and both the percentage difference and the per-serving quantitative amounts need to appear per 101.54(e)(1)(iii) and 101.13(j)(2). As with the absolute source claims, the percentage is calculated from unrounded, as-analyzed amounts, not from the panel’s 101.9(c)-rounded display.
On the label
A loaf of bread with a RACC of 50 g (21 CFR 101.12) fortified to 6% DV iron, versus your standard loaf at 3% DV iron, clears the 10%-more test (a 100% relative increase). The label needs: “More iron: this bread has 6% DV iron per serving vs. 3% DV in our regular bread”, naming the reference food and giving both the percentage difference and the quantitative amounts. Build the /product-labels/bread/ panel for both versions; the comparison numbers come from the same recipe analysis.
Mistakes we see
- Making the claim without the comparison statement. 101.54(e)(1)(iii) and 101.13(j)(2) both require the reference food’s identity and the percentage difference in immediate proximity to the claim, not buried elsewhere on the package.
- Comparing to an inappropriate reference food. 101.13(j) requires the comparison run against a similar food, not an arbitrary competitor chosen to inflate the percentage.
- Assuming “fortified” is automatically fine because it clears 10%. 101.54(e) is a labeling-format rule; 21 CFR 104.20’s fortification policy is a separate question about whether FDA considers adding that nutrient to that food category appropriate in the first place.
- Skipping the quantitative comparison. The percentage-difference statement alone isn’t enough; 101.13(j)(2)(iv) also requires quantitative amounts per labeled serving for both products.
- Voiding an exemption. Like every other nutrient content claim, this one is incompatible with the reduced-format and no-panel options under 101.9(j)(4) and (j)(13).
Related claims
See Good source / Contains / Provides and High / Excellent source of for the absolute versions of the RDI/DRV percentage test this claim borrows its nutrient list from, and Healthy for the separate food-group-based implied claim. Background: /labeling-rules/nutrient-content-claims/ and /labeling-rules/rounding-rules/.
Check your label
The NutriLabels builder’s claims check compares your product’s analyzed nutrient values against a reference food you provide, on the same RDI/DRV basis this rule uses, and tells you whether you clear the 10% threshold and what the required comparison statement needs to say.
A “fortified” claim printed with its comparison statement in place tells a shopper exactly what your reformulation added. Enter your recipe, then see your label: the calorie count, the nutrient content claims you qualify for and your allergen line show free, no card required, while 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 browse the other nutrient content claims.
More / Added / Extra / Fortified / Enriched [nutrient] claim FAQ
What nutrients can carry a "more" or "fortified" claim?
Vitamins and minerals (measured against the RDI) and protein, dietary fiber, or potassium (measured against the DRV), per 21 CFR 101.54(e)(1)(i). It's the same nutrient list as good source and excellent source, because all three claims run off the same RDI/DRV framework (21 CFR 101.54).
What has to appear next to the claim itself?
Two things, per 21 CFR 101.54(e)(1)(iii): the identity of the reference food and the percentage or fraction the nutrient is higher, declared in immediate proximity to the claim; and quantitative amounts comparing the product to the reference food, declared adjacent to the claim or on the nutrition label (21 CFR 101.54).
Is "fortified" only about vitamins and minerals I add during manufacturing?
The claim itself is nutrient-agnostic: it just requires 10% more of an RDI/DRV nutrient than a reference food. Whether FDA considers the underlying addition of that nutrient appropriate in the first place is a separate question addressed by the fortification policy at 21 CFR 104.20 (21 CFR 104.20).
Can I pick any competitor's product as my reference food?
No. Under 21 CFR 101.13(j)(1)(i)(B), the reference food for a 'more'/'fortified'/'added' claim must be a similar food, such as one brand of multivitamin compared to another, not a dissimilar substitute. Under 101.13(j)(1)(ii)(B), its nutrient value may be your own regular product, a competitor's regular product offered for sale on a regular basis in the same geographic area, or an average value from a representative database, the top brands, or a market-basket norm, not an unrelated product chosen because it makes the percentage look bigger.
Does this claim also need the disqualifying-level disclosure?
Yes, on the same basis as any other nutrient content claim: if the food exceeds 13 g fat, 4 g saturated fat, 60 mg cholesterol, or 480 mg sodium per RACC, per labeled serving, or per 50 g (for small RACCs), 21 CFR 101.13(h) requires a disclosure statement (21 CFR 101.13).
Related claims
Good source of [nutrient], High in / Rich in / Excellent source of [nutrient], Healthy. See the full all label claims.