Reduced Sugar Claim: The FDA 25% Rule and Reference Food

Last verified 17 Sep 2026 · Sources

“Reduced sugar” (and its variants “less sugar,” “lower sugar,” “reduced in sugar,” “sugar reduced,” “lower in sugar”) requires at least 25% less sugars per Reference Amount Customarily Consumed (RACC) than an appropriate reference food (21 CFR 101.60(c)(5)(i)). Unlike “sugar free,” this is a relative claim. It needs a named reference food and a required comparison statement, not just a standalone number. The trap you’re most likely to hit: getting the 25% math right but leaving off the mandatory statement identifying the reference food and the percentage difference, which 21 CFR 101.13(j)(2) requires in immediate proximity to the claim itself.

Quick facts	Reduced sugar
Regulation	21 CFR 101.60(c)(5)
Threshold	≥25% less sugars per RACC than an appropriate reference food
Claim type	relative
Reference food needed	Yes
Disclosure statement	Not applicable (this is a comparison statement requirement, not a disqualifying-nutrient disclosure)
Wordings FDA allows	Reduced sugar, Reduced in sugar, Sugar reduced, Less sugar, Lower sugar, Lower in sugar

What the rule says

21 CFR 101.60(c)(5) permits “reduced sugar,” “reduced in sugar,” “sugar reduced,” “less sugar,” “lower sugar,” or “lower in sugar” on the label or in labeling of foods (except meal products as defined in 101.13(l), main dish products as defined in 101.13(m), and dietary supplements of vitamins or minerals), provided:

(c)(5)(i): “The food contains at least 25 percent less sugar per reference amount customarily consumed than an appropriate reference food as described in § 101.13(j)(1).”

(c)(5)(ii): the claim must meet the disclosure requirement in 101.13(j)(2) for relative claims generally.

101.13(j)(1) sets the ground rules for any relative claim (light, reduced, less, more, fewer): “A relative claim… must be made on the basis of a comparison with a reference food, and the identity of the reference food and the percent (or fraction) that the nutrient differs must be declared in immediate proximity to the most prominent such claim.” 101.13(j)(2) spells out the wording itself: 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]’)”. For sugar, that’s “25% less sugar than [reference food],” naming the food specifically.

On “reduced added sugar”: 101.60 defines this claim by total sugars (the same figure measured under 101.9(c)(6)(ii)), not by added sugars specifically. The phrase “reduced added sugar” does not appear anywhere in 21 CFR 101.60. FDA has not created a distinct comparative claim for added sugars the way it did for total sugars. If your product cut only its added sugars (say, by adding more naturally sugary fruit while removing cane sugar), it still has to clear the 25% bar on total sugars. FDA’s guidance on added sugars does not address this claim by name; the regulation text governs.

The numbers

Threshold: at least 25% less sugars per RACC than the reference food. There’s no small-RACC per-50 g test here, since that test applies to “low” (absolute) claims, not relative ones.
Reference food rules (101.13(j)(1)): the reference food has to be an “appropriate” comparator: ordinarily the same type of food, most commonly your own regular version (Original Granola Bars vs. new Reduced Sugar Granola Bars). A dissimilar food or an outdated recipe risks the claim not holding up.
Rounding interplay (101.9(c)): the 25% figure is computed from the actual analyzed values in both products, not the already-rounded panel numbers, especially near the threshold.
Required statement format: per 101.13(j)(2), state the reference food’s identity and the percentage difference together, next to the claim, not the percentage alone, and not buried elsewhere on the pack.

On the label

Granola bars (/product-labels/granola-bars/) are a common candidate, since many recipes lean on honey, brown rice syrup, or chocolate coating. If the Original bar analyzes at 10 g sugars per RACC and a reformulated version comes in at 7 g or less (a 30% cut), “Reduced Sugar” is available, provided the front-of-pack claim carries a line like “30% less sugar than our Original Granola Bars (10 g vs. 7 g sugar per bar),” placed near the claim itself, not buried on the back panel.

Mistakes we see

Skipping the reference-food statement. The most common gap: the 25% cut is real, but nothing on the label names the reference food or states the percentage next to the claim, which 101.13(j)(2) requires.
Comparing to the wrong reference food. A dissimilar product, a discontinued recipe, or a food that isn’t a fair “appropriate reference food” under 101.13(j)(1) undermines the claim’s basis.
Trying this on a meal or main dish product. 101.60(c)(5) explicitly excludes meal products (101.13(l)) and main dish products (101.13(m)).
Voiding a small-package exemption. Printing “reduced 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.
Assuming “less added sugar” is the same defined claim. Because 101.60 measures total sugars, if your product reduced only its added sugars, it still has to run the 25% test against total sugars.

Check your label

The NutriLabels builder’s claims check compares your reformulated recipe against your reference product on every basis the rule names and tells you whether you clear 25%, and gives you the exact comparison wording 101.13(j)(2) requires, not just the percentage.

A “Reduced Sugar” claim with its comparison line in place lets your reformulation do the selling on the front of the pack. 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 compare no added sugar.

Reduced sugar claim FAQ

Does the FDA have a separate "reduced added sugar" claim?

No. 21 CFR 101.60 defines 'reduced sugar' by total sugars, not added sugars specifically, and the phrase 'reduced added sugar' does not appear in the section. The comparative claim in 101.60(c)(5) is for total sugars.

Can a meal product or main dish use "reduced sugar"?

21 CFR 101.60(c)(5) expressly excludes meal products as defined in 101.13(l), main dish products as defined in 101.13(m), and dietary supplements of vitamins or minerals from this claim.

What has to appear next to the "reduced sugar" claim?

21 CFR 101.13(j)(2) requires the label to state the identity of the reference food and the percentage or fraction the nutrient differs by, in immediate proximity to the most prominent claim, for example, '25% less sugar than our Original Granola Bars.'

Can I compare my product to a competitor's product instead of my own prior recipe?

Yes, within limits. Under 21 CFR 101.13(j)(1)(i)(B), a 'reduced' claim's reference food must be a similar food, a granola bar compared to a granola bar, not a dissimilar substitute. Under 101.13(j)(1)(ii)(B), the nutrient value for that reference food may be your own regular product, or another manufacturer'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 a single competitor product picked because it makes the percentage look better.

Does "reduced sugar" also let me drop the sugar disclosure on the ingredient list?

No. 'Reduced sugar' only concerns the quantity comparison in 101.60(c)(5). It doesn't touch the ingredient-list or sugar-alcohol declaration rules in 101.9(c)(6), which apply independently based on what the product actually contains.

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