"No Added Sugar" Muffins

An “all natural bakery,” whose products can be found in natural foods stores, labels its packaged muffins “no sugar added.” 

The first listed ingredient (and therefore the most predominant by weight) in these muffins is chicory syrup, which is a sweetener. A common misconception among consumers and manufacturers is that “no added sugar” can be used for any product that contains no white/refined sugar. U.S. labeling law does not define “no added sugar” this way. The term “sugar” encompasses many kinds of caloric sweeteners (“all free mono- and disaccharides”), which include honey and syrups such as chicory syrup. Additionally, use of “any other ingredient that contains sugars that functionally substitute for added sugars” would preclude use of the phrase “no added sugar.” Clearly, these muffins do contain added sugars, because chicory syrup is a “sugar” and it is functioning as a sugar/sweetener. And even if the product did not contain “added sugars,” in order to use the claim, it would need to include a statement that the food is not “low calorie” or “calorie reduced” (unless it truly is… see Blooper 151). (21 CFR 101.60(c)(2))

Additional notes on this product: A claim of “no trans fat” is made, when only the statement “0 g trans fat” is allowed by law. The shelf life date (a little over one week) is too long for a fresh, unpreserved, highly sweetened and moist bakery product (i.e., it’s a veritable bacteria/mold magnet).

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