Last verified 16 Sep 2026 · Sources
FDA’s nutrient content claims aren’t marketing language. Each is a defined numeric threshold under 21 CFR 101.13 and 101.54 through 101.62. “Low sodium” means 140 mg or less per reference amount customarily consumed (RACC); “sodium free” means less than 5 mg; “fat free” means less than 0.5 g; “good source of” a vitamin or mineral means 10 to 19 percent of the Daily Value per RACC, while “high” or “excellent source” means 20 percent or more. Miss the exact number and the claim is non-compliant, not merely optimistic.
| Quick facts | Nutrient content claims |
|---|---|
| Regulation | 21 CFR 101.13, 101.54, 101.56, 101.60, 101.61, 101.62 |
| Applies to | Any label carrying low, free, reduced, light, good source, or high claims |
| Key numbers | Low sodium ≤140mg/RACC; sodium free <5mg; fat free <0.5g; sugar free <0.5g; good source 10–19%DV; high ≥20%DV |
The rule
21 CFR 101.13 sets the general framework: an expressed claim directly states a nutrient level (“low sodium”), while an implied claim suggests one without stating it directly, such as “made with oat bran” to suggest a fiber benefit, for instance (21 CFR 101.13). Both are regulated the same way: if the wording implies a nutrient level, that level has to meet the defined threshold.
The individual thresholds live in their own sections: 101.54 for “good source,” “high,” and “more”; 101.56 for “light”/”lite”; 101.60 for sugar and calorie claims; 101.61 for sodium claims; 101.62 for fat and cholesterol claims. Each defines “free,” “low,” and “reduced” with its own number, and most specify a stricter version for “meal” and “main dish” products measured per 100 g instead of per RACC.
A separate provision, 101.13(h), requires a disclosure statement (“See nutrition information for [fat/saturated fat/cholesterol/sodium] content”) printed in bold next to any claim on a food exceeding set levels of fat, saturated fat, cholesterol, or sodium, so “high in fiber” can’t sit next to a high-sodium product unflagged.
The numbers
| Claim | Threshold | Section |
|---|---|---|
| Calorie free | <5 calories per RACC and per labeled serving | 101.60 |
| Low calorie | ≤40 calories per RACC (RACC >30g/2 tbsp) | 101.60 |
| Reduced calorie | ≥25% fewer calories than reference food | 101.60 |
| Sugar free | <0.5 g sugars per RACC and per labeled serving | 101.60 |
| Reduced/less sugar | ≥25% less sugar than reference food | 101.60 |
| Sodium free | <5 mg per RACC and per labeled serving | 101.61 |
| Very low sodium | ≤35 mg per RACC | 101.61 |
| Low sodium | ≤140 mg per RACC | 101.61 |
| Reduced/less sodium | ≥25% less sodium than reference food | 101.61 |
| Fat free | <0.5 g per RACC and per labeled serving | 101.62 |
| Low fat | ≤3 g per RACC | 101.62 |
| Reduced/less fat | ≥25% less fat than reference food | 101.62 |
| Saturated fat free | <0.5 g sat fat and <0.5 g trans fat per RACC | 101.62 |
| Low saturated fat | ≤1 g per RACC, ≤15% calories from sat fat | 101.62 |
| Cholesterol free | <2 mg per RACC and per labeled serving | 101.62 |
| Low cholesterol | ≤20 mg per RACC and ≤2 g saturated fat | 101.62 |
| Good source of | 10–19% DV per RACC | 101.54 |
| High / rich in / excellent source | ≥20% DV per RACC | 101.54 |
| Light / lite | ≥33⅓% fewer calories or ≥50% less fat than reference food | 101.56 |
| Light in sodium | ≥50% less sodium than reference food | 101.56 |
| Disclosure statement triggers | >13.0 g fat, >4.0 g sat fat, >60 mg cholesterol, or >480 mg sodium per RACC | 101.13(h) |
Meal and main dish products generally use per-100 g versions of these thresholds rather than per-RACC.
On the label
Say you make jerky and want “good source of protein” on the bag. The RACC for jerky is 30 g. If one 30 g serving delivers 10 to 19% of the protein DV, “good source” is accurate; hit 20% or more, and “excellent source of protein” is the correct, stronger claim instead. Printing “excellent source” at 14% DV would be a violation.
Or say you make hot sauce and want “low sodium.” The RACC for hot sauce (a minor condiment) is 1 teaspoon, a tiny serving that makes 140 mg or less achievable for most hot sauces, unlike a soup or dressing at a larger RACC. The claim has to be checked against that 1-teaspoon RACC, not a per-bottle total.
Mistakes we see
- Checking the claim against the wrong serving size. Thresholds are per RACC, not your own serving guess. See what-is-racc.
- Confusing “reduced” with “low.” “Reduced sodium” only requires a 25% cut from a reference product; it doesn’t mean the food meets the “low sodium” number.
- Using “light” for a cut under the threshold. A 20% fat reduction doesn’t qualify: “light” needs 50% or more fat reduction, or a one-third calorie cut.
- Skipping the disclosure statement. A “good source of fiber” claim on a food also high in sodium still needs the “See nutrition information for sodium content” line past 101.13(h) levels.
- Making an implied claim without checking a defined term. Wording or imagery suggesting “low fat” is still an implied claim FDA can hold to the numeric standard.
Related rules
Every threshold above is measured against the RACC in what-is-racc, and %DV comes from the calculation in percent-daily-value. Claims beyond a nutrient level, like a disease-risk statement, move into health-claims territory. If you rely on the small business exemption, read small-business-exemption, since any claim here cancels that exemption.
Get the claims checked before they’re printed
Verifying a claim means running the exact numbers for a recipe against the RACC and the relevant section above, not eyeballing a lab report.
A claim checked against your real numbers stays true on every reprint, even after a recipe change. The Studio plan ($299 a year: every product you make, plus the compliance binder and PDF reports) checks claim thresholds against each product’s actual formulation as recipes change, with history so a reformulation that breaks a claim shows up before the next print run, and the Co-packer plan ($1,199 a year: everything in the Studio plan plus client folders and white-label documents) adds the same for consultants. For a single product with one claim to verify, enter your recipe, then see your label: your calories, the claims you qualify for and your allergen line are free, no card required, every other value and %DV stays hidden until you unlock, and Single Product ($29) unlocks every other nutrient value and %DV, every FDA format your product qualifies for, and your ingredient statement and allergen declaration. See pricing or try the free label builder to see the free preview first.
FAQ
What sodium level counts as "low sodium"?
140 mg or less of sodium per reference amount customarily consumed (RACC), or per 100 g for meal/main dish products, under 21 CFR 101.61.
What's the difference between "free" and "low" for fat, sugar, and sodium?
'Free' means the amount is small enough to round to essentially zero (for example, less than 0.5 g of fat or sugar, less than 5 mg of sodium, per RACC and per labeled serving). 'Low' allows a small measurable amount: 3 g or less of fat, or 140 mg or less of sodium, per RACC.
How much of the Daily Value does a food need for "good source" versus "high"?
'Good source' requires 10 to 19 percent of the RDI or DRV per RACC; 'high,' 'rich in,' or 'excellent source' requires 20 percent or more, per 21 CFR 101.54.
What triggers the "See nutrition information for ___ content" disclosure statement?
Under 21 CFR 101.13(h), a claim on a food exceeding 13.0 g of fat, 4.0 g of saturated fat, 60 mg of cholesterol, or 480 mg of sodium per RACC (or per 50 g for foods with a small RACC) must carry this disclosure next to the claim.
How much of a reduction does "reduced" require?
At least 25 percent less of the nutrient than an appropriate reference food. The same 25 percent threshold applies across reduced fat, reduced saturated fat, reduced sodium, reduced sugar, and reduced calorie claims.
What does "light" require?
At least a one-third reduction in calories or a 50 percent reduction in fat compared to a reference food, under 21 CFR 101.56; 'light in sodium' requires a 50 percent or greater sodium reduction.
Related rules
Health claims, Percent Daily Value (%DV), What is a RACC?, Small business exemption. See the full all labeling rules.
Sources
- ecfr.gov/current/title-21/chapter-I/…101/subpart-D/section-101.13
- ecfr.gov/current/title-21/chapter-I/…101/subpart-D/section-101.54
- ecfr.gov/current/title-21/chapter-I/…101/subpart-D/section-101.56
- ecfr.gov/current/title-21/chapter-I/…101/subpart-D/section-101.60
- ecfr.gov/current/title-21/chapter-I/…101/subpart-D/section-101.61
- ecfr.gov/current/title-21/chapter-I/…101/subpart-D/section-101.62