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FDA’s Guidance on Added Sugars is as Thick as Molasses

FDA released a draft Guidance statement on how food companies should calculate the added sugar content in their products for the purposes of nutrition labeling.  Comments are due on March 6.

Guidance documents are supposed to help simplify FDA regulations (added sugars content is required to be disclosed on Nutrition Facts labels  starting July 26, 2018), but the agency’s attempts at explaining its regulatory requirements in this case are as thick as molasses.  The guidance document on added sugars labeling is in the form of questions and answers.  It runs 12 pages and is filled with detailed instructions to perform complicated calculations.  It turns out that disclosing added sugars is not as simple as we were led to believe.  For example, do fruit concentrates need to be declared as added sugars (in some cases, yes, but it depends), or do sugars from fermentation count as added sugars (once again, it depends).

In response to the following question about fruit punch, “How should I calculate the amount of added sugars in a fruit juice blend containing the juice of multiple fruits that have not been reconstituted to 100 percent full strength,” the agency provides the following, less than concise, explanation:

“Example 1: a manufacturer produces a fruit juice blend with apple juice concentrate, mango juice concentrate, pear juice concentrate and water (assuming a serving size of 240 g):% formulation

% sugar in single strength juice (21 CFR 101.30) – use Brix value as estimates

10% concentrated apple juice (46% sugar)

11.5% sugar

10% concentrated mango juice (39% sugar)

13% sugar

20% concentrated pear juice (24% sugar)

12% sugar

Water (60%)

Water (60%)

Method 1:

We know the final weight of the actual reconstituted juice blend (A). We then calculate the final weight of the juice blend if it were reconstituted to 100 percent juice (B). Because the juice blend has a greater sugar content than single strength juice, the weight of juice blend, A, would be less than B. Therefore, juice blend A is, in effect, concentrated even though it has water added to it, and the concentration factor is calculated as B/A. We can then use this concentration factor to calculate the amount of added sugars in a serving of the juice blend. In the example below, we first calculate the amount of added sugars based on 100 grams and then convert the result to determine the amount of added sugars in a 240 g serving.

Column 1

Column 2

Column 3

Column 4

Column 5

Percent of each juice in the formulation (100 g)

Weight of juice concentrate1

Amount of sugar from juice concentrate2

Amount of water needed to reconstitute to single strength for juice concentrate3

Percent sugar in single strength juice4

10% concentrated apple juice (46% sugar)

100 x 10% = 10 g

100 x 10% x 46% = 4.6 g

4.6/11.5% – 10 = 30 g

11.5% sugar

10% concentrated mango juice (39% sugar)

100 x 10% = 10 g

100 x 10% x 39% = 3.9 g

3.9 / 13% – 10 = 20 g

13% sugar

20% concentrated pear juice (24% sugar)

 

100 x 20% = 20 g

100 x 20% x 24% = 4.8 g

4.8/12% – 20= 20 g

12% sugar

1Weight of each ingredient = 100 g × percent of juice in the formulation

2Amount of sugar from juice concentrate = 100 g × percentage of juice in the formulation × percentage sugar in the juice concentrate

3Amount of water needed to reconstitute to concentrated juice to single strength = Amount of sugar from juice concentrate / percentage sugar in single strength juice – weight of initial juice concentrate

4Brix values in 21 CFR 101.30(h) are used as estimates.

On a 100 g basis, the calculation goes like this:

  • The final weight of the actual reconstituted juice blend (A) = 100 g.
  • The final weight of the juice blend if it were reconstituted to 100% juice (B) = Total water needed to reconstitute to single strength (form column 4) + total weight of the concentrated juice (from column 2) = (30 g + 20 g + 20 g) + (10 g +10 g + 20 g) = 110 g
  • The concentration factor = B / A = 110 / 100 = 1.1
  • Total sugar (from column 3) = 4.6 g + 3.9 g + 4.8 g = 13.3 gm
  • The amount of added sugar = total sugar – sugar in single strength juice blend = 13.3 g -13.3 g / 1.1 g = 1.21 g

On serving size basis, the calculation is as follows:

  • The amount of added sugar = (serving size / 100 g) × (the amount of added sugar per 100g) = (240 g / 100 g) × 1.21 g = 2.9 g.”

The agency provides a second alternative method that is just as complicated.  After reading FDA’s Guidance meant to clear up confusion about added sugars labeling, one gets the feeling that the agency’s attempt at guidance is one more reason this regulation should be delayed and re-evaluated by the incoming Trump Administration.

Sugar was singled out by the Obama administration as the primary cause for the incidence of a variety of diseases. Basic facts were ignored, particularly the fact that U.S. per capita consumption of sugar and other caloric sweeteners is not rising, but falling (by 15% since 1999) and sweeteners’ share of per capita food consumption has declined by 9% since 1970. Federal regulations like this one should be based on scientific evidence and established by traditional procedures.  For starters, the National Academy of Medicine should conduct a study of sugars and all carbohydrates to determine recommended intakes, as has been the case for every nutrient required to be disclosed on the Nutrition Facts label other than sugars.  

The only matter cleared up by the agency’s Guidance document is that FDA’s decision to declare added sugars on the Nutrition Facts Label needs to be re-visited prior to the 2018 compliance deadline.

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