"No Added Sugar!"

[kaylasdad99]

I see this on a lot of labels of things at the supermarket lately. I presume that it means that the processing plant that manufactured the item does not use refined sugar as an ingredient in the recipe. Fructose-laden ingredients such as fruit juice evidently do not disqualify items from bearing the label.

But what if I wanted to make a batch of Twinkies at my commercial bakery, and I wanted to label them as “No Added Sugar”? I could put the sugar in the mixing vat FIRST, meaning that it was all the OTHER ingredients that were added, right?

[TimeWinder]

@kaylasdad99

I could put the sugar in the mixing vat FIRST, meaning that it was all the OTHER ingredients that were added, right?

The FDA and the FCC both frown on deliberately misleading claims, and it’s hard to argue this could be anything else.

[Smeghead]

Here’s the legal definition:

(2) The terms “no added sugar,” “without added sugar,” or “no sugar added” may be used only if:

(i) No amount of sugars, as defined in 101.9(c)(6)(ii), or any other ingredient that contains sugars that functionally substitute for added sugars is added during processing or packaging; and

(ii) The product does not contain an ingredient containing added sugars such as jam, jelly, or concentrated fruit juice; and

(iii) The sugars content has not been increased above the amount present in the ingredients by some means such as the use of enzymes, except where the intended functional effect of the process is not to increase the sugars content of a food, and a functionally insignificant increase in sugars results; and

(iv) The food that it resembles and for which it substitutes normally contains added sugars; and

(v) The product bears a statement that the food is not “low calorie” or “calorie reduced” (unless the food meets the requirements for a “low” or “reduced calorie” food) and that directs consumers’ attention to the nutrition panel for further information on sugar and calorie content.

From here.

If your using sugar in excess of what is naturally part of your other ingredients, I don’t think you can legally claim “no added sugar”. Nowhere is the order of addition of ingredients to the mixer considered.

[Ethilrist]

Wow…

(iv) The food that it resembles and for which it substitutes normally contains added sugars; and

That’s a bitch… if EVERYBODY ELSE is saying it, YOU have to say it, even if you DON’T add any sugar.

[Smeghead]

That’s not how I read it. I understand it to say that if most applesauces add sugar to their mix, and you don’t add it to yours, then you can say “No added sugar”.

[Inner_Stickler]

Right, so you can’t stick “No Added Sugar” on your bag of flour and hope to get some sales from idiots who don’t know what flour is.

[ZipperJJ]

Yeah it means you can’t add “no added sugar!” to your bag of baby carrots, because no one adds extra sugar to baby carrots.

[obfusciatrist]

I’ve eaten at restaurants with no added sugar desserts where one of them was caramel. I wondered about that.

[PorchePine]

What about Asbestos Free! on the label?

[Octarine]

Or advertise asbestos-free cereal . . .
ETA: Ninja’d!

[Amateur_Barbarian]

Right, but if one of your ingredients is fruit juice, then you didn’t “add any sugar.” The sugar game has gotten impossibly byzantine. An ingredient that’s come along in recent years is “highly reduced (or highly concentrated) fruit juice” which is - wait for it - nearly pure fructose.

But it sounds so… healthy!

[Inner_Stickler]

@Amateur_Barbarian

Right, but if one of your ingredients is fruit juice, then you didn’t “add any sugar.” The sugar game has gotten impossibly byzantine. An ingredient that’s come along in recent years is “highly reduced (or highly concentrated) fruit juice” which is - wait for it - nearly pure fructose.

But it sounds so… healthy!

(i) No amount of sugars, as defined in 101.9(c)(6)(ii), or any other ingredient that contains sugars that functionally substitute for added sugars is added during processing or packaging; and

(ii) The product does not contain an ingredient containing added sugars such as jam, jelly, or concentrated fruit juice; and

I mean, I don’t know, maybe Libby’s has an end-run around that too, but they’re trying.

[Amateur_Barbarian]

What if “concentrated fruit juice” is an ingredient, not an additive? See the difference? I don’t know if such hair-splitting would work, in the short or long run, but I know the labeling game has gotten utterly Orwell-visits-Wonderland in recent decades.

[Chronos]

If you’re using concentrated fruit juice, then you just don’t say “No added sugar!” on the label-- Instead, you say “100% fruit juice!”.

[Lips_Obsession]

@ZipperJJ

Yeah it means you can’t add “no added sugar!” to your bag of baby carrots, because no one adds extra sugar to baby carrots.

But you could advertise it as “Low Fat” - just like Twizzlers does… (of course carrots would be no fat…)

[Exapno_Mapcase]

@Amateur_Barbarian

What if “concentrated fruit juice” is an ingredient, not an additive? See the difference? I don’t know if such hair-splitting would work, in the short or long run, but I know the labeling game has gotten utterly Orwell-visits-Wonderland in recent decades.

It would work up to the minute you’re caught, like most crimes.

[RivkahChaya]

@Smeghead

That’s not how I read it. I understand it to say that if most applesauces add sugar to their mix, and you don’t add it to yours, then you can say “No added sugar”.

I once had to plan meals for a woman who was autistic, diabetic, and had no teeth. “No sugar added” applesauce was a staple of her diet. She got some sugar from it, and diabetics need some, in a form that was released a little differently than it would be if we’d given her an Oreo, and it had fiber. So, yeah, in some cases, that label is very useful. This client was really into repetition and predictability, so she liked having applesauce frequently, and it was hard to get her to eat her meals quickly. Her first doctor who was a GP kept insisting that we had to give her her shot first, and then make her eat in X time, no matter what it took. I finally got her to an endocrinologist who had a lot of children on his caseload, who had us test her blood before the meal, and then time the shot for X amount of time into the meal, and test her again after she finished eating. It was an extra test, but she didn’t mind the stick at all. She really minded being harassed to eat faster. Her bedtime blood sugars, and her evening moods really improved after that.
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