Often found on packaging are claims that describe directly or imply the level of a nutrient in a serving. These claims are limited to those nutrients which are authorized by the FDA, and have established Daily Values. These types of claims can be used without direct review by the FDA, however there is still compliance based on the Code of Federal Regulations that must be adhered to.
Nutrients that qualify for nutrient content claims are Calories, Total Fat, Saturated Fat, Cholesterol, Dietary Fiber, Sugars, Protein, Vitamins (Vitamin A, Vitamin C, Vitamin D, Vitamin E, Folate, Vitamin B12, Biotin, Pantothenic acid, Vitamin K, Thiamin, Riboflavin, Niacin, Vitamin B6, Choline), Minerals (Potassium, Calcium, Iron, Sodium, Iodine, Magnesium, Chromium, Molybdenum, Chloride, Zinc, Selenium, Copper, Manganese), and ALA omega-3 fatty acids. ALA omega-3 fatty acid is only able to have nutrient content claims due to the ‘Martek Notification’.
Nutrient content claims key words most often found in labeling are based on the product’s reference amount and those include…
Free: means the product contains an insignificant amount of Total Fat, Saturated Fat, Cholesterol, Sodium, Sugars, or Calories. Allowable synonyms include “zero, without, trivial source of, negligible source of, and ‘non-fat’ is a synonym for fat-free”.
Low: means a product does not exceed the guidelines in multiple servings for Total Fat, Saturated Fat, Cholesterol, Sodium, or Calories. Allowable synonyms include “little, few, contains a small amount of, and low source of”.
- It is important to note that nutrient content claims have not been defined for carbohydrates, trans fat, and “low” sugar. So, use of those claims is not permissible. If a claim is made about cholesterol, then polyunsaturated fat and monounsaturated fat must be included in the Nutrition Facts.
|Calories||Less than 5 calories per serving||40 calories or less per serving|
|Total Fat||Less than 0.5g fat per serving and contains no ‘fat’ containing ingredients unless ingredient is footnoted with “adds a trivial amount of fat”||3g or less fat per serving|
|Saturated Fat||Less than 0.5g saturated fat and less than 0.5g trans-fat per serving and contains no ‘saturated fat’ containing ingredients unless ingredient is footnoted with “adds a trivial amount of saturated fat”||1g or less of saturated fat per serving and not more than 15% calories from saturated fat|
|Sodium||Less than 5mg of sodium per serving and contains no ‘sodium chloride (table salt)’ containing ingredients unless ingredient is footnoted with “adds a trivial amount of sodium”||140mg or less sodium per serving|
|Cholesterol||Less than 2mg of cholesterol and 2g or less saturated fat per serving and contains no ‘cholesterol’ containing ingredients unless ingredient is footnoted with “adds a trivial amount of cholesterol”||20mg or less of cholesterol and 2g or less of saturated fat per serving|
Good: means the product contains 10-19% of the Daily Value of a nutrient (i.e. protein, fiber, or vitamin or mineral). Synonyms include “contains and provides”.
High: means the product contains 20% or more of the Daily value of a nutrient (i.e. protein, fiber, vitamin or mineral). Synonyms include “excellent source and rich in”.
- Notes to remember about “good” and “high” claims are they cannot be used to describe nutrients without established Daily Values. If a fiber claim is made and the food doesn’t qualify for “low fat”, then a disclosure must accompany the statement which discloses the level of total fat per serving. Also, if a protein claim is made, then the Nutrition Facts must include the % Daily Value calculated using the PDCAAS score (protein digestibility corrected amino acid score).