Last verified 16 Sep 2026 · Sources
Trans fat gets its own line on the Nutrition Facts label under 21 CFR 101.9(c)(2)(ii), and any serving with less than 0.5 gram rounds down to “0g”. No %Daily Value is shown, because FDA hasn’t set one for this nutrient. Separately, FDA determined in 2015 that partially hydrogenated oils (PHOs), the main source of industrially produced trans fat, are no longer generally recognized as safe for use in food, with a compliance date of June 18, 2018 that was later extended to January 1, 2021 for products already moving through distribution (fda.gov). Naturally occurring trans fat in meat and dairy is unaffected by the PHO determination and still gets declared on the label like any other trans fat.
| Quick facts | Trans fat |
|---|---|
| Regulation | 21 CFR 101.9(c)(2)(ii) |
| Applies to | Any packaged food required to carry a Nutrition Facts label with fat content |
| Key numbers | Below 0.5g per serving rounds to 0g; no %DV required; PHO compliance dates June 18, 2018 and January 1, 2021 |
The rule
21 CFR 101.9(c)(2)(ii) defines trans fat for labeling purposes as “the sum of all unsaturated fatty acids that contain one or more isolated (i.e., nonconjugated) double bonds in a trans configuration” (law.cornell.edu). It’s declared in grams per serving on its own indented line under saturated fat. The same paragraph sets the rounding instruction: “If the serving contains less than 0.5 gram, the content, when declared, shall be expressed as zero.”
Unlike total fat or saturated fat, trans fat carries no %DV column on the panel: FDA has not established a Daily Value reference for trans fat, so only the gram figure appears.
The trans fat definition doesn’t separate industrial sources (like partially hydrogenated oils) from the trans fat that occurs naturally in the fat of ruminant animals (cattle, sheep, and goats) as a byproduct of digestion. Both counts are added together into the single trans fat figure on the label; there’s no separate “natural trans fat” line.
Regulating the ingredient itself is a different action from the Nutrition Facts rule. In 2015, FDA finalized its determination that PHOs are no longer GRAS for use in human food. FDA set June 18, 2018 as the date after which manufacturers generally could not add PHOs to foods, then extended the final compliance date to January 1, 2021 “to allow for an orderly transition in the marketplace” and let already-manufactured products work through distribution (fda.gov). PHOs are no longer GRAS and cannot be added to food.
Separately, 21 CFR 101.13(i)(3) treats a plain factual statement of a nutrient amount (FDA’s own example is “100 calories” or “5 grams of fat”) as not an implied nutrient content claim, “in which case no disclaimer is required,” provided the statement doesn’t characterize the level and isn’t misleading (law.cornell.edu). A statement of the amount as it appears on the panel, such as “0g Trans Fat,” is a factual nutrient statement under that provision, while a claim such as “trans fat free” is a nutrient content claim FDA has not defined.
The numbers
- Rounding threshold: below 0.5 g trans fat per serving → declared as “0g.”
- %DV: none required or permitted for trans fat; FDA has not set a Daily Value.
- PHO GRAS determination: finalized 2015.
- PHO compliance date (general use): June 18, 2018.
- PHO compliance date (products already in distribution): extended to January 1, 2021.
On the label
Say your cracker recipe uses a small amount of shortening containing partially hydrogenated soybean oil, contributing 0.3 g trans fat per labeled serving. Because 0.3 g is below the 0.5 g threshold, the Nutrition Facts panel correctly shows “Trans Fat 0g”. That’s not a loophole, it’s the rounding rule working as written. The ingredient statement still lists the fat source by name, so a trans-fat-sensitive shopper reading past the panel can still see it.
Now say you make jerky with beef fat, which naturally contains a small amount of trans fatty acids as part of normal ruminant fat composition. If that trans fat content is 0.6 g per serving, it’s declared as “Trans Fat 0.6g” on the label. The natural origin doesn’t exempt it from declaration or push it under the rounding threshold on its own; only the actual gram amount does.
Mistakes we see
- Assuming “0g Trans Fat” on the panel means the product contains no PHO or trans fat at all, rather than less than 0.5 g per serving.
- Leaving trans fat off the panel entirely for products with naturally occurring trans fat in dairy or meat fat, on the assumption that only industrial PHO trans fat counts.
- Adding a %DV figure next to the trans fat line, when no Daily Value exists for this nutrient.
- Confusing the ingredient-level PHO phase-out (a food-additive regulatory action) with the label-level trans fat rounding rule (a Nutrition Facts declaration rule). They’re related but separate requirements.
- Building a front-of-pack “trans fat free” marketing claim without checking that the underlying rounding-based “0g” actually reflects the product’s real formulation after every ingredient change.
Related rules
Trans fat rounds the same way whole-number nutrients do; see rounding rules for the general increments across the panel. Since trans fat carries no %DV, compare it with how %DV is calculated for nutrients that do have a Daily Value. Claims that touch fat content, including “trans fat free,” fall under nutrient content claims, and sweetener-related claims that often appear alongside fat claims are covered in added sugars.
Build it right
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FAQ
Why does a label say '0g Trans Fat' when the ingredient list has partially hydrogenated oil?
Because 21 CFR 101.9(c)(2)(ii) requires rounding to zero for any serving with less than 0.5 gram of trans fat, even when the food contains a small amount. FDA also requires the ingredient itself to be declared, so the presence of partially hydrogenated oil can still show up in the ingredient statement even at a rounded 0g trans fat level.
Is there a %Daily Value for trans fat?
No. FDA has not established a Daily Value for trans fat, so the Nutrition Facts label shows only the gram amount, with no %DV column, for this nutrient.
Are partially hydrogenated oils banned from food?
FDA determined PHOs are no longer generally recognized as safe (GRAS) for use in human food, with a compliance date of June 18, 2018 for most uses, later extended to January 1, 2021 to let products already in distribution work through the market. A narrow set of specific, FDA-authorized uses can still exist outside general food use.
Does naturally occurring trans fat in meat and dairy have to be declared?
Yes. The trans fat definition in 101.9(c)(2)(ii) doesn't distinguish between industrially produced trans fat and the small amounts that occur naturally in ruminant meat and dairy fat. Both are declared the same way on the label.
Can I put 'zero trans fat' as a claim on my front label?
A factual statement of the gram amount, like '0g Trans Fat,' is generally treated as a factual nutrient statement rather than an implied claim under 21 CFR 101.13(i)(3), as long as it isn't misleading. Whether a specific front-of-pack claim needs additional disclosure depends on the rest of your label. Talk to a food-labeling attorney if you're unsure.
Related rules
Added Sugars, Nutrient content claims, Percent Daily Value (%DV), Rounding rules. See the full all labeling rules.