Important News and Developments

Food Labelers Beware: Carbohydrate Labeling is Tricky

Del Mar, CA – March 1, 2004 – Food Consulting Company, specializing in the preparation of regulation-compliant food label components for the food industry, cautions manufacturers to study food labeling regulations of the Food and Drug Administration (FDA) before choosing “carb” phrases for food labels. Label wording that might seem logical to communicate carbohydrate content to consumers might not be allowed by the FDA.

"The simplest, most direct phrase, 'low carb' for example is not allowed on food labels,” explained Karen Duester, president of Food Consulting Company. FDA regulations for nutrient content claims (21CFR101.13) permit labels to describe the level of certain nutrients in a product using the term low, but FDA has not established values for carbohydrate in relation to claims; therefore, the term "low” cannot be used in association with the term carbohydrate (or carb) on food labels.

Referring to the FDA regulations, Duester said the terms Free, Zero, No, Without, Trivial Source of, Negligible Source of, Dietarily Insignificant Source of, Low, Little, Few, Contains a Small Amount of, Low Source of, Reduced, Less, Lower, Fewer, and any synonyms of these words are disallowed to describe carbohydrate content on food labels. However food labelers may make an accurate quantitative statement of fact (e.g., 5g carbohydrate per serving), as long as the statement does not characterize the amount of carbohydrate present. A statement such as "only 5g carbs" for example, is not allowed since the word “only” characterizes the level of carbohydrate as low.

Duester further explained that FDA regulations do not disallow the terms “net carbs”, “net impact carbs” or “net effective carbs” to describe carbohydrate content on food labels. These terms are being used by the food industry to reflect the amount of carbohydrate a product contains that will impact blood glucose levels. The value is derived from the formula, net carbs = total carbohydrates – dietary fiber – sugar alcohols.

Food labelers can receive fast and accurate carbohydrate labeling help from Food Consulting Company, or they can refer to FDA’s Food Labeling Guide, available at; a summary of allowed nutrient content claims can be found in appendix A.

Food Consulting Company, based in Del Mar, CA, is the largest out-source provider assisting food companies in meeting FDA and USDA labeling requirements. The company offers a full range of food labeling services including product analysis (both database and laboratory), nutrition facts panels, ingredient statements, full label compliance packages, shelf life evaluations, final label reviews, and INTOUCH, a free monthly email newsletter that keeps food companies informed on government action affecting food labels. Duester can be reached through the company web site at, or by calling 800-793-2844.