Gluten-free muffin mix nutrient claims

A gluten-free pumpkin muffin mix is described on the packaging and/or website with claims of "low carb," "4 g protein" and "rich in magnesium, vitamin A and vitamin E." The Nutrition Facts show 8% DV for vitamin C.


Although this product may have fewer grams of carbohydrate than a typical muffin, there is no definition for "low carb,"  and as such it cannot be used as a nutrient claim in food labeling. And even if there were a defined claim of "low carb," this product would most likely not meet the criteria, as the 14 grams of carbohydrate here make up 62% of all the calories in each small 90-calorie serving.

As for the 4 g protein, that is "per serving as prepared," and the "as prepared" nutrition data is not given in the labeling, only the nutrition for the amount of mix in one serving. Whenever a claim is made for nutrition in the "as prepared" version of a product (e.g., with egg and oil added), the nutrition "as prepared" MUST be shown in a separate column in the Nutrition Facts.

The product is indeed "rich in" (i.e., at least 20% DV for) magnesium, but it does not even come close to meeting the criteria for "rich in" vitamin A or vitamin E (it provides only 2% DV and 4% DV, respectively). The amount of vitamin C shown (8% DV) is impossible for the ingredients and their degree of processing.


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