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Nutrition Labels 101: What's Required? What's Optional?

The demand for reliable nutrition information is increasing. More consumers are elevating their health consciousness, particularly with the rising number of concerns about the increasing levels of obesity in our population. Heart disease is the leading cause of death in the United States every year—accounting for 1 in every 4 deaths—so it’s no wonder why Americans are buckling down on the food they're putting in their bodies.1

Detailed nutrition information is one of the best ways food manufacturers can encourage consumers to make good decisions with regard to their eating habits—but food companies aren't required to list every nutrient in the food they provide.

Trans fat increases LDL cholesterol (i.e., "bad" cholesterol) but also lowers HDL cholesterol (i.e., "good" cholesterol). So it's a bit of a nutritional double whammy.

"Required" nutrients are those the U.S. Food and Drug Administration (FDA) has determined impact common health issues—weight control, diabetes, high blood pressure, heart disease, stroke, and many others—and should be disclosed.

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"Optional" nutrients, on the other hand, (see Table 1) are those that are less important to consumer awareness (e.g., a rarity of certain vitamin deficiencies) or because they fit under a broader nutrition label requirement (e.g., soluble fiber is a part of dietary fiber). The FDA requires nutrients that fall into one of these categories be listed on a nutrition label only when it’s necessary to bolster or prove the label's food label or marketing claim.

To best help consumers make informed decisions about their food choices, the FDA says all nutrition labels must include these 13 components.

Nutrition Labels: What’s Required?

1. Serving Sizes and Servings per Package

Serving sizes and servings per package are arguably the most important part of a nutrition label, since all nutrition fact information is based on the particular serving size. Laboratory analyses are typically reported in units that are standard for the analytical community—usually in units per 100 grams—which can then be converted to label information, expressed in quantities per serving.

The importance of serving sizes was recognized in 1990 with the passing of the Nutrition Labeling and Education Act.2 It was understood that consumers had difficulty comparing one product to another. To remedy this, the USFDA and USDA now require the use of standard reference serving sizes in the nutrition facts panel.

Household units such as cups, tablespoons, teaspoons, pieces, or fluid ounces are to be used to express serving size, followed by the metric equivalents in milliliters or grams. In some cases, the amount commonly consumed per eating occasion is the serving size.

A bag of chips might have a serving size of six chips, instead of a standard measurement. Special rules apply to products sold in packages that are expected to be consumed in one eating occasion but are significantly smaller or larger than the reference amount.3

2. Calories

Calories, the unit measuring the energy in food, is one of the most important requirements included in the fact panel. Calories per serving can be expressed in one of two ways:

  • For servings with 50 calories or less, the number must be expressed in increments of 5
  • For servings with over 50 calories, the number must be expressed in increments of 10

Calories may be determined by a number of methods, but all calories must be calculated and added together before rounding, regardless of the method used.

3. Total Fat

Total fat states just that—the total grams of fat per serving, including all lipid fatty acids expressed as triglycerides. The FDA recommends using the AOAC Official Method of Analysis 996.06 to determine the total fat per serving.4 If the total fat is less than 0.5 grams per serving, it can be expressed as zero on the nutrition label, but it still must be listed.

4. Saturated Fat

"Saturated" fat is the sum of all fatty acids containing no double bonds. Though it’s under the umbrella of total fat, saturated fat is listed separately, since saturated fats are considered “bad fats” because they raise your LDL cholesterol levels. You can find saturated fats, which are solid at room temperature, in animal products like meat, cheese, and butter.

Note, the FDA uses the terms “saturated fat” and “saturated fatty acids” interchangeably, but they refer to the same thing. Similar to total fat, if saturated fat is less than 0.5 grams per serving, it can be expressed as zero, but still must be listed.

5. Trans Fat

Trans fat is the worst of the “bad fats,” which is why in 2006 the FDA began requiring it to be listed separately on nutrition labels. Trans fat, like saturated fat, increases LDL cholesterol levels (i.e., "bad" cholesterol) but also lowers HDL cholesterol levels (i.e., "good" cholesterol). So it's a bit of a nutritional double whammy.

Trans fat is most often found in oils that have been processed using a method called partial hydrogenation.5 The FDA has used “trans fatty acids” and “trans fat” interchangeably, the same way it uses “saturated fatty acids” and “saturated fat.”6 Though the FDA is slowly phasing out the use of trans fat, food manufacturers are still required to include it on nutrition labels.7 Just like total fat and saturated fat, if there are less than 0.5 grams of trans fat per serving, it can be expressed as zero.

Table 1: Nutrition Labels 101: What's Optional?
Calories from Fat Other Carbohydrates Riboflavin (Vitamin B2)
Polyunsaturated Fat Vitamin A Niacin (Vitamin B3)
Monounsaturated Fat Vitamin C Folate
Soluble Fiber Vitamin E Vitamin B12
Insoluble Fiber Vitamin K Biotin
Phosphorous Thiamin (Vitamin B1) Pantothenic Acid
Sugar Alcohols Iodine  Magnesium

6. Cholesterol

Cholesterol is a substance similar to fat that’s essential for your body to build cells, but too much can cause build-up in your arteries. The cholesterol listing on nutrition labels notes the cholesterol content of the food per serving in milligrams rounded to 5 mg increments.

If the amount of cholesterol contained is less than 2 milligrams per serving, it can be stated as zero in the nutrition fact panel, or replaced with the statement “Not a significant source of cholesterol” at the bottom of the table. If the food or food product contains 2-5 milligrams of cholesterol per serving, the content may be stated as “contains less than 5 milligrams.” Both LDL and HDL cholesterols are included under this label.

7. Sodium

Sodium is an essential mineral for the human body, helping to maintain fluid balance and muscle contraction, making it a mandatory listing on nutrition labels. But, too much sodium can lead to high blood pressure, heart disease, stroke, and a bevy of other ailments.

Sodium must be stated in milligrams of sodium per serving. It’s expressed as zero when there’s less than 5 mg present, in 5 mg increments when containing 5-140 mg, and in 10 mg increments for amounts greater than 140 mg per serving.

8. Total Carbohydrates

"Total" carbohydrates is the sum of three nutrients in food: dietary fiber, sugars, and starches. Total carbohydrates is a required listing unless there is less than 1 gram, at which point it can be expressed as “contains less than 1 gram,” or if less than 0.5 grams per serving, it can be expressed as zero.

Sugars are the sneaky nutrient found naturally in many "healthy" foods, including fruit and milk.

Total carbohydrate content is determined by calculation. The sum of the contents of crude protein, total fat, moisture, and ash are subtracted from 100 to give “total carbohydrate,” thus requiring each of the four assays before the calculation can be carried out.

Here's a pro tip: If you’re looking to find total starch in the food you’re eating, subtract the dietary fiber and sugars from total carbohydrates, and you have your starch.

9. Dietary Fiber

Dietary fiber is the only carbohydrate your body can’t digest, which means it actually supports overall digestive health. Dietary fiber is expressed in grams, except in quantities of less than 1 gram which may state “contains less than 1 gram."

A declaration of dietary fiber content is not required if the statement “not a significant source of dietary fiber” is included at the bottom of the table. Like other ingredient disclosures, if a serving has less than 0.5 grams of dietary fiber, zero may be used.

10. Sugars

Sugars are the sneaky nutrient found naturally in many “healthy” foods, including fruit and milk. Sugars are defined as all free mono and disaccharides—fructose, glucose, sucrose, maltose, and lactose—in a serving, and must be listed in grams, except for quantities of less than 1 gram which may state “contains less than 1 gram.”

Added Sugars are now listed below the line for Total Sugars on the FDA's new Nutrition Facts label.

A declaration of sugar content or category is not required if the statement “not a significant source of sugars” is placed at the bottom of the nutrition facts table. Again, if a serving has less than 0.5 grams of sugars per serving, zero may be used.

11. Protein

Protein is an incredibly important nutrient. Our bodies use protein to build and repair tissues, including hair, nails, bones, muscles, skin, and blood. We also use it to make enzymes, hormones, and other body chemicals. Grams of protein in a serving is expressed to the nearest gram, except for quantities of less than 1 gram which may state “contains less than 1 gram.” If a serving has less than 0.5 grams of protein per serving, zero may be used.

If a percent Daily Reference Value (DRV) of the protein is disclosed on the label, the protein “quality factor” must be determined. Due to cost and difficulty in determining quality factors, many nutritional labels do not include DRV.

12. Vitamin D, Potassium, and Minerals

If proteins are the “builders” of your body, vitamins and minerals are the maintenance crew, working to keep you consistently healthy. Vitamin D, Potassium, and the minerals, calcium and iron, will now state exact amounts along with their daily value percentage.

Vitamins A and C will no longer be required on the FDA's Nutrition Facts labels (though manufacturers may still include them if they choose), while Vitamin D and Potassium will now be required.

The percent of the daily value is expressed in 2% increments from 2-10% of the daily value; in 5% increments from 10 to 50% of the daily value; and in 10% increments if the level is above 50%.

At a level less than 2%, a declaration of zero, or a statement regarding the fact that there is less than 2% or not a significant source can be used.

The updated nutrition facts label requirements must be implemented by January 1, 2020, (or January 1, 2021, for companies that have less than $10 million in annual sales). There will be some leniency early on, as products packaged on or before December 31, 2019, will be allowed to keep the current Nutrition Facts label until the product is out of date.

The Bottom Line

There are a lot of nutrition label requirements—there’s no doubt about that. Accurate testing and detailed nutrition labels are more important now than ever before with the growing rate of food-related health issues in the United States. With the help of the FDA’s requirements, you can help protect consumers by encouraging them to make healthy, informed food choices for themselves and their families.

Just when you thought you were up to speed on what's required and what's optional to disclose on your nutrition label, the FDA goes and adjusts it. Don't worry, we've got you covered. Check out the nutrition label changes coming in 2020.

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  1. https://www.cdc.gov/heartdisease/docs/ConsumerEd_HeartDisease.pdf
  2. https://www.fda.gov/iceci/inspections/inspectionguides/ucm074948.htm
  3. https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.9
  4. https://files.instrument.com.cn/bbs/upfile/2008622221856.pdf
  5. https://www.mayoclinic.org/healthy-lifestyle/nutrition-and-healthy-eating/in-depth/fat/art-20045550
  6. https://www.fda.gov/OHRMS/DOCKETS/98fr/94p-0036-nfr0001.pdf
  7. https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/LabelingNutrition/ucm385663.htm