SAFEGUARDS | Food NO. 009/17

SafeGuardS Customers with small kids purchasing jam

On January 4, 2017, the US Food and Drug Administration (US FDA) issued a draft guidance of answers to questions about the compliance date, labeling of added sugars, rounding of the quantitative amounts of vitamins and minerals and label formats [1]. They also issued a second draft guidance, with examples of food products in categories for the Reference Amounts Customarily Consumed (RACCs) per Eating Occasions [2]. The industry and public have 60 days to comment on these two guidance documents.

Compliance Date

While the compliance dates have not changed, July 26, 2018 ($10,000,000 or more annual food sales) and July 26, 2019 (less than $10,000,000 annual food sales), the US FDA has clarified that products must be labeled on or after these compliance dates with the new nutrition facts panel. The $10,000,000 annual food sales figure is based on all human food sales, domestic and international. This can be determined by taking the lowest annual food sales of the previous three year period (i.e. 2013, 2014, 2015) or taking the average of this three year period.

Rounding of Quantitative Amounts of Vitamins and Minerals

The US FDA provided a chart to the industry on the rounding rules for vitamins and minerals.

SafeGuardS 00917 Figure 1

Labeling of Added Sugars

In this guidance, the US FDA clarified what is not added sugar. US FDA excludes whole fruit, fruit pieces, dried fruit, pulps and purees from the added sugar definition. They also excluded 100 percent fruit and vegetable juice concentrates when they are used to manufacture juice, jellies, jams and preserves, or when these 100 percent juice concentrates are sold directly to consumers (frozen concentrated orange juice). The US FDA in this document provided methods to help the industry calculate the “added sugars” amount.


This guidance provides more details about which items are listed in the RACC category as well as clarification that even if ingredients are in separate packets when sold together if they are consumed at the same time, that may be considered the combination of that product. As follows is a small example of this guidance document:

SafeGuardS 00917 Figure 2

What Does This Mean For The Food Industry?

The food industry needs to take the time to learn about and understand the requirements before analyzing for nutritional/supplemental amounts and developing labels. Therefore, SGS recommends using food labeling experts who understand the difference between what is required and what is allowed on the new US nutrition and supplement fact panels.

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Food Scientific and Regulatory Affairs Manager

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