Updating Supplement Facts labeling of added sugars

CRN Member query:

“We are in the process of converting to the new Supplement Facts label format for 2020, and we’ve come across a couple of questions regarding how to properly label added sugars. If we have an actual added sugars value of less than 0.5 gram per serving, are we required to declare added sugars on the Supplement Facts label? If omitted, are we required to include the statement ‘Not a significant source of added sugars’ on the label?”

CRN's Andrea Wong, Ph.D., responds:

There are differences between labeling requirements for foods and those for dietary supplements, and they can be confusing. For labeling of dietary supplements, as indicated in 21 CFR 101.36(b)(2), “Any (b)(2)-dietary ingredients that are not present, or that are present in amounts that can be declared as zero in 21 CFR 101.9(c), shall not be declared.  The (b)(2)-dietary ingredients include added sugars. Added sugars in an amount less than 0.5 gram per serving can be declared as zero under 21 CFR 101.9(c), which specifies requirements for nutrition labeling of food. Therefore, if a supplement product contains less than 0.5 gram of added sugars per serving, declaration of added sugars is not required on the Supplement Facts label. In contrast, if a food product contains less than 0.5 gram of added sugars per serving, the amount of added sugars may be declared as “0 g” on the Nutrition Facts label, or not declared at all (unless a claim is made about sweeteners, sugars, added sugars, or sugar alcohol content.) Additionally, while the statement “Not a significant source of added sugars” is required on the Nutrition Facts label when added sugar is not declared, the same statement is not required on the Supplement Facts label when added sugar is not declared.