Last verified 16 Sep 2026 · Sources
Declaring sugar alcohol grams on a Nutrition Facts label is voluntary until your label makes a claim about sugar alcohols, sugars, or added sugars, at which point 21 CFR 101.9(c)(6)(iv) makes the declaration mandatory. A “sugar free” gummy bear sweetened with maltitol has to show the sugar alcohol line; a plain candy with no sugar-related claim doesn’t. When it’s declared, each sugar alcohol carries its own FDA-assigned calorie value per gram, which is why two “sugar free” products with the same gram count of sweetener can show different total calories.
| Quick facts | Sugar alcohols |
|---|---|
| Regulation | 21 CFR 101.9(c)(6)(iv) |
| Applies to | Foods containing erythritol, xylitol, sorbitol, maltitol, or other sugar alcohols |
| Key numbers | Erythritol 0 kcal/g; xylitol 2.4; maltitol 2.1; sorbitol 2.6; isomalt & lactitol 2.0; mannitol 1.6 |
The rule
21 CFR 101.9(c)(6)(iv) states: “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” (law.cornell.edu). The regulation defines sugar alcohols as “saccharide derivatives in which a hydroxyl group replaces a ketone or aldehyde group,” which covers erythritol, xylitol, sorbitol, maltitol, lactitol, mannitol, isomalt, and hydrogenated starch hydrolysates.
The same paragraph gives you a naming shortcut: “In lieu of the term ‘sugar alcohol,’ the name of the specific sugar alcohol (e.g., ‘xylitol’) present in the food may be used in the nutrition label provided that only one sugar alcohol is present in the food.” So a product sweetened only with erythritol can list “Erythritol 8g” directly instead of the generic “Sugar Alcohol” line; a product blending two or more sugar alcohols reports them under the combined “Sugar Alcohol” label.
Sugar alcohols sit on their own line on the Nutrition Facts panel, indented under total carbohydrate alongside total sugars and dietary fiber, but they are counted separately from both total sugars and added sugars. A sugar alcohol is never itself a “sugar” or an “added sugar” for labeling purposes, even where it displaces sugar in a reduced-sugar reformulation.
The numbers
FDA’s caloric conversion factors for sugar alcohols, from 21 CFR 101.9(c)(1)(i)(F), assign each type its own calories-per-gram value used to calculate total calories on the label (law.cornell.edu):
| Sugar alcohol | Calories per gram |
|---|---|
| Erythritol | 0 |
| Mannitol | 1.6 |
| Isomalt | 2.0 |
| Lactitol | 2.0 |
| Maltitol | 2.1 |
| Xylitol | 2.4 |
| Sorbitol | 2.6 |
| Hydrogenated starch hydrolysates | 3.0 |
21 CFR 101.9(c)(6)(iv) states this rounding convention directly for sugar alcohols: declared “to the nearest gram, except that if a serving contains less than 1 gram, the statement ‘Contains less than 1 gram’ or ‘less than 1 gram’ may be used,” and if the serving contains less than 0.5 gram, the content may be expressed as zero, the same convention used for total carbohydrate.
On the label
Take a “sugar free” hard candy sweetened entirely with xylitol. Because the front label makes a sugar-related claim, the sugar alcohol line is mandatory: “Sugar Alcohol 3g” (or “Xylitol 3g,” since it’s the only sugar alcohol present) has to appear under total carbohydrate, and those 3 g contribute 3 × 2.4 = 7.2 calories toward the calorie count, rounded per the calorie-rounding rule. If you declare “0g sugar” but leave the calorie line unchanged because “it’s sugar alcohol, not sugar,” the math is wrong: the calories still count.
Now take a granola bar sweetened with a small amount of maltitol syrup as a humectant, with no “sugar free,” “no sugar,” or “reduced sugar” claim anywhere on the package. You can choose to declare the sugar alcohol grams anyway for transparency, or leave the line off the panel entirely. Both are compliant, because no qualifying claim triggered the requirement.
Mistakes we see
- Making a “sugar free” or “no added sugar” claim without adding the now-mandatory sugar alcohol declaration line.
- Using a single generic calorie factor (like the old 4 kcal/g default for carbohydrate) for every sugar alcohol instead of the compound-specific value.
- Listing multiple sugar alcohols under one specific name (like “Xylitol”) when more than one type is actually present, which only the single-type shortcut in (c)(6)(iv) allows.
- Assuming a sugar alcohol lowers total carbohydrate or fiber grams. It’s part of total carbohydrate, reported alongside sugars and fiber, not subtracted from them.
- Forgetting that erythritol’s 0 kcal/g value is the exception, not the rule, and applying it to other sugar alcohols in the calorie calculation.
Related rules
Sugar alcohols interact closely with added sugars rules, since a “sugar free” claim almost always touches both lines, and with dietary fiber where a fiber-and-sugar-alcohol blend affects total carbohydrate math. For the claim thresholds themselves (what actually qualifies as “sugar free”), see nutrient content claims, and for how the gram values round on the panel, see rounding rules.
Build it right
Our builder applies the correct calorie factor for each sugar alcohol you enter (erythritol at 0 kcal/g, xylitol at 2.4, maltitol at 2.1, and so on) and flags when a sugar-related claim on your label requires the sugar alcohol line to be shown.
A “sugar free” claim backed by the right sugar alcohol line and calorie math is one a shopper can take at its word. 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 your ingredient statement and allergen declaration, ready to print. Start your label or check the nutrient content claims thresholds for “sugar free.”
FAQ
Do I have to list sugar alcohols on the Nutrition Facts label?
Only if you make a claim about sugar alcohols, sugars, or added sugars where sugar alcohols are present in the food (like 'sugar free'). Otherwise, declaring the gram amount is voluntary under 21 CFR 101.9(c)(6)(iv).
Can I just say 'Sugar Alcohol' instead of naming which one?
Yes, if only one type of sugar alcohol is in the food. If the product contains more than one, each has to be named, or the generic term 'Sugar Alcohol' covers the combined total instead. Check your builder's format for which the panel supports.
Do all sugar alcohols have the same calorie count?
No. FDA assigns a specific calorie value per gram to each: erythritol is the only one at 0 kcal/g, while others range from 1.6 to 3.0 kcal/g depending on the specific compound.
Does a sugar alcohol count toward total sugars or added sugars?
No. Sugar alcohols are declared separately from both total sugars and added sugars on the Nutrition Facts label; they aren't sugars for labeling purposes even though they taste sweet.
Why do some 'sugar free' candies still have calories?
Because most sugar alcohols aren't zero-calorie. A candy sweetened with maltitol (2.1 kcal/g) or sorbitol (2.6 kcal/g) still contributes meaningful calories, even with zero added sugar.
Related rules
Dietary Fiber, Added Sugars, Nutrient content claims, Rounding rules. See the full all labeling rules.