What Exactly Does the FDA Mean by 'No Added Sugars'?
The FDA's nutrition labelling regulations define 'no added sugars' to mean that no sugar, sugar-based syrup, honey, or concentrated fruit juice was added as an ingredient during manufacturing or processing. It also means no ingredients were added that contain added sugars, such as jam or fruit paste sweetened with cane sugar.
Crucially, the definition targets the production step, not the finished product's total sugar content. A food like dried fruit can still carry the claim even though it is high in naturally occurring sugars, provided nothing extra was stirred in. This distinction is worth understanding before reading any label at face value.
The FDA's Code of Federal Regulations, Title 21, is the primary reference for these definitions. Manufacturers who make the claim without meeting the criteria risk enforcement action, which the openFDA enforcement database sometimes reflects in warning letters.
Which Sweeteners Do Brands Use to Maintain Sweetness Without Added Sugar?
When a formula drops cane sugar, brown sugar, or high-fructose corn syrup, something else usually takes over the sweetening role. The most common substitutes fall into three broad groups: high-intensity natural sweeteners, synthetic non-nutritive sweeteners, and concentrated plant sugars that regulators classify separately from 'added sugars'.
High-intensity natural sweeteners include stevia leaf extracts (listed on labels as rebaudioside A or steviol glycosides) and monk fruit extract (listed as Luo Han Guo fruit extract or mogroside V). Both are permitted by the FDA as generally recognized as safe (GRAS) and deliver sweetness at a fraction of the quantity needed for sugar, so they contribute negligible calories.
Synthetic options such as sucralose, acesulfame potassium (ace-K), and aspartame are FDA-approved food additives governed by the FDA colour and food additive listings. They appear frequently in beverages, flavoured yogurts, and protein snacks carrying no-added-sugar claims. Their safety profiles have been assessed by the FDA, though debate about long-term metabolic effects continues in nutrition research and is not yet settled.
- Rebaudioside A / steviol glycosides — from the stevia plant, GRAS status
- Mogroside V / monk fruit extract — from Luo Han Guo fruit, GRAS status
- Sucralose — FDA-approved synthetic sweetener, ~600 times sweeter than sugar
- Acesulfame potassium (ace-K) — FDA-approved, often blended with other sweeteners
- Aspartame — FDA-approved, not suitable for people with phenylketonuria
Do Fruit Juice Concentrates Count as Added Sugar?
This is one of the most debated corners of food labelling. Concentrated fruit juice is a common sweetening agent in products such as fruit bars, granola, and yogurt drinks. Under the FDA's current rules, juice concentrate used as an ingredient does count as an added sugar and must be reflected in the 'added sugars' line of the Nutrition Facts panel.
However, a product may still claim 'no added sugars' if the only juice used is 100% juice concentrate and the label also carries a statement explaining that the product is not low in naturally occurring sugars. This nuance trips up many shoppers. Checking what ingredients appear in the top five of the ingredient list helps clarify how much concentrate is actually present.
Open Food Facts, a crowd-sourced food product database, shows numerous products where fruit concentrate appears as the second or third ingredient, meaning it constitutes a meaningful proportion by weight. That level of concentration can push total sugar per serving well above what a comparable conventionally sweetened product might contain.
What Role Do Dietary Fibers Play in 'No Added Sugar' Products?
Several soluble dietary fibres have a mild sweetness and are added to no-added-sugar products partly to restore bulk and mouthfeel that sugar would otherwise provide. Inulin and chicory root fibre are two common examples. They also appear on fibre-content marketing, making them doubly attractive to formulators.
These fibres are not sugars and do not raise blood glucose the way sucrose does, according to research cited in USDA FoodData Central nutrient data. However, they are fermented in the large intestine, which can cause bloating or gas in people sensitive to fermentable carbohydrates—a group sometimes guided by low-FODMAP dietary advice.
Other bulking agents such as erythritol (a sugar alcohol) serve a similar structural role. Erythritol is largely absorbed in the small intestine and excreted unchanged, so it contributes minimal calories and does not cause the same level of fermentation discomfort as inulin. It appears on ingredient lists by name.
How Do Manufacturers Keep Texture and Mouthfeel Without Sugar?
Sugar does far more than sweeten. It affects the moisture retention, browning, crystalline structure, and perceived thickness of a food. Removing it forces formulators to rebuild those properties using other ingredients.
Maltodextrin, a processed starch derived from corn or wheat, is a frequent bulking agent in no-added-sugar baked goods and protein bars. It has a very high glycaemic index—higher than table sugar—yet it is classified as a carbohydrate rather than a sugar, so it does not appear in the added sugars line. USDA FoodData Central lists its carbohydrate contribution clearly.
Glycerol (also called glycerin) is another texture agent used to keep products moist. It is FDA-approved as a food-grade humectant. It provides about 4.3 calories per gram, slightly more than sugar, though it is metabolised differently and has a very mild sweetness. Spotting it on a label tells you the manufacturer is working hard to replicate sugar's physical properties.
What Ingredients Should You Look for When Comparing Products?
Rather than relying on the front-of-pack claim alone, scanning the ingredient list for the first three to five entries gives the most honest picture of what is sweetening the product. Ingredients appear in descending order by weight under FDA labelling rules, so whatever is listed first is present in the greatest amount.
Beyond sweeteners, watch for maltodextrin high in the list (it raises the carbohydrate load without counting as sugar), and check whether the Nutrition Facts panel shows a meaningful total sugar figure from naturally occurring sources. A no-added-sugar fruit yogurt, for instance, can still contain 15–20 grams of total sugar per serving from milk lactose and fruit.
InZoRAH can walk through each ingredient in a specific product's list, cross-referencing databases including USDA FoodData Central and Open Food Facts, so you can see at a glance whether the sweetness is coming from a high-intensity sweetener, a concentrate, or a bulking agent—and what a comparable product nearby might look like.
- Check positions 1–5 in the ingredient list for sweetening agents
- Look at the 'Added Sugars' sub-line in the Nutrition Facts panel
- Note whether total sugars are high even if added sugars read zero
- Identify bulking agents like maltodextrin separately from sweeteners
- Confirm whether the product carries a required disclosure statement about naturally occurring sugars
Are 'No Added Sugar' Products Automatically Healthier?
Not automatically. The claim signals something specific about the manufacturing process, not the overall nutritional quality of the food. A biscuit sweetened with ace-K and bulked with refined white flour still lacks meaningful fibre, vitamins, or protein.
Some research tracked through nutrition science literature suggests that very sweet tastes—regardless of source—may maintain a preference for sweet foods over time, though this area is not fully settled. The FDA's general position is that non-nutritive sweeteners are safe when consumed within acceptable daily intake levels, which are set well above typical dietary exposure.
Reading what ingredients make up a product in full—not just the sweetener—is the most reliable way to judge whether it fits a particular eating pattern. Always check the physical label if you have an allergy or medical condition, as formulations can change.
| Ingredient | Type | Calorie contribution | Typical label name |
|---|---|---|---|
| Rebaudioside A | Natural high-intensity sweetener | Negligible | Stevia leaf extract |
| Mogroside V | Natural high-intensity sweetener | Negligible | Monk fruit extract |
| Sucralose | Synthetic non-nutritive sweetener | Negligible | Sucralose |
| Acesulfame potassium | Synthetic non-nutritive sweetener | Negligible | Ace-K |
| Erythritol | Sugar alcohol | ~0.2 kcal/g | Erythritol |
| Inulin / chicory root fibre | Soluble dietary fibre / bulking agent | ~1.5 kcal/g | Chicory root fibre |
| Maltodextrin | Processed starch / bulking agent | ~4 kcal/g | Maltodextrin |
| Fruit juice concentrate | Natural sugar source | ~2.8–3 kcal/g | Concentrated apple juice |
