[US Food Labeling] Interpretation of Nutrition Facts of Regular Food and Dietary Supplements

Food labels in the US must comply with the requirements of American federal regulations – 21 CFR 101.9 for general food and 21 CFR 101.36 for dietary supplements. To convey the correct nutrition facts to consumers, label makers should fully understand the requirements of food labels and ensure that every detail is standardized. In this article, we will provide a detailed interpretation of the requirements of US nutrition labels.

Regular Food

• The basic format of nutrition facts

Fig.1 Basic format of nutrition facts (Appendix B to Part 101, Title 21)

• Label

The labels must be read as “Nutrition Facts”.

• Calorie calculation

The content of energy-yielding nutrients in each serving (before modification) was multiplied by the respective corresponding calorie conversion factors (see Table 1) and summed, and the numerical results were labeled according to the modification rules in Table 2. (21 CFR 101.9(c)(1)(i))

Table 1: Calorie conversion factors of energy-yielding nutrients in each serving

Nutrient	Conversion factors calories/g	Nutrient	Conversion factors calories/g	Nutrient	Conversion factors calories/g
Protein	4	Isomaltitol	2	Sorbitol	2.6
Carbohydrates	4	Lactitol	2	Hydrogenated starch hydrolysate	3
Fats	9	Xylitol	2.4	Mannitol	1.6
Dietary Fiber	2	Maltitol	2.1	Erythritol	0

• Nutrient details

The Nutrition Facts must label the 15 mandatory items in Table 2 in the order in which they are listed. Other vitamins and minerals are labeled voluntarily but are required to be labeled when they are added as a nutrient-enhancing additive or when they are the subject of a content claim (21 CFR 101.9(c)(8)(ii)). The order of labeling for other vitamins and minerals is shown in Table 3, and the order and modification rules for mandatory items is shown in the table below.

Table 2: Order and modification rules for mandatory items

Nutrient	Label modification rules	Regulations
Calories	<5 cal - expressed as 0 5-50 cal - Expressed to the nearest 5 cal increment >50 cal - Expressed to the nearest 10 cal increment	21 CFR 101.9(c)(1)
Total Fat	<0.5 g - expressed as 0 g 0.5-5 g - Expressed to the nearest 0.5 g increment >5 g - expressed to the nearest 1 g increment	21 CFR 101.9(c)(2)
Saturated Fat
Trans Fat
Cholesterol	<2 mg - expressed as 0 mg 2-5 mg - Expressed to <5 mg >5 mg - expressed to the nearest 5 mg increment	21 CFR 101.9(c)(3)
Sodium	<5 mg - expressed to 0 mg 5-140 mg - expressed to the nearest 5 mg increment >140 mg - expressed to the nearest 10 mg increment	21 CFR 101.9(c)(4)
Total Carbohydrate	<0.5 g - expressed as 0 g 0.5-1 g - expressed to <1 g >1 g - expressed to the nearest 1 g increment	21 CFR 101.9(c)(6)
Dietary Fiber
Total Sugar
Includes X g Added Sugars
Protein		21 CFR 101.9(c)(7)
Vitamin D	<2% RDI - %DV expressed as 0 2-10% RDI - %DV expressed to the nearest 2% increment 10-50% RDI - %DV expressed to the nearest 5% increment >50% RDI - %DV expressed to the nearest 10% increment	21 CFR 101.9(c)(8)
Calcium
Iron
Potassium

• %DV calculation and its footnote

%Daily Value, referred to as %DV, is the percentage of labeled value (or value before modification) of each serving to daily nutrient reference values (DRVs/RDI) for that nutrient, expressed to the nearest 1 percent increment (21 CFR 101.9(d)(7)(ii)), except for vitamins-minerals (the modification rules for vitamins-minerals (excluding sodium) are the same as those for vitamin D in Table 2).

DRVs/RDI for adults and children aged 4 and above are listed in table 3.

Table 3 DRVs/RDI reference values（adults and children aged 4 and above as an example）

RDI
Vitamin D	20 mcg	Biotin	30 mcg
Calcium	1,300 mg	Pantothenic acid	5 mg
Iron	18 mg	Phosphorus	1,250 mg
Potassium	4,700 mg	Iodine	150 mcg
Vitamin A	900 mcg	Magnesium	420 mg
Vitamin C	90 mg	Zinc	11 mg
Vitamin E	15 mg	Selenium	55 mcg
Vitamin K	120 mcg	Copper	0.9 mg
Thiamin	1.2 mg	Manganese	2.3 mg
Riboflavin	1.3 mg	Chromium	35 mcg
Niacin	16 mg	Molybdenum	45 mcg
Vitamin B6	1.7 mg	Chloride	2,300 mg
Folate	400 mcg DFE	Choline	550 mg
Vitamin B12	2.4 mcg	Protein	/
DRVs
Fat	78 g	Sodium	2,300 mg
Saturated Fat	20 g	Dietary Fiber	28 g
Cholesterol	300 mg	Protein	50 g
Total carbohydrate	275 g	Added Sugars	50 g

Note: DFE = Dietary Folate Equivalents; 1 mcg DFE=0.6 mcg folic acid.

No DRVs/RDIs for trans fats, or total sugars, there is no need to list %DV. If the product is intended for use by the general population 4 years of age and older and there is no claim on the label for protein content (e.g., high protein content), there is no need to list the %DV for protein.

%Daily Value* footnote: *The % Daily Value tells you how much a nutrient in a serving of food contributes to a daily diet. 2,000 (or 1,000， depending on the population) calories a day is used for general nutrition advice.（21 CFR 101.9(d)(9)）

Dietary Supplement

• The basic format of supplement facts

Fig. 2 Basic format of supplement facts

• Title

The title must be read as “Supplement Facts”.

• Calorie calculation

Calorie calculation in the Supplement Facts is the same as that for regular food but does not need to be conspicuously labeled. When calories per serving are <5cal, calories do not need to be labeled in the Supplement Facts.

• Dietary supplement details

(1) Regular ingredients

The order must be listed as the following: calories, total fat, saturated fat, trans fat, cholesterol, total carbohydrates, dietary fiber, total sugars, added sugars, protein, vitamin A, vitamin C, vitamin D, vitamin E, vitamin K, thiamine, riboflavin, niacin, vitamin B6, folate, vitamin B12, biotin, pantothenic acid, choline, calcium, iron, phosphorus, iodine, magnesium, Zinc, Selenium, Copper, Manganese, Chromium, Molybdenum, Chloride, Sodium, Potassium, and Fluoride (21 CFR 101.36(b)(2)). The above ingredients that are not present or are expressed as zero according to the modification rules for the Nutrition Facts (see Table 2) are not labeled in the Supplement Facts.

(2) Other ingredients

Probiotics, curcumin, must be listed below and separated from those in (1) by a bold horizontal line. If it is a botanical ingredient, the Latin name and part of the source must be listed. (21 CFR 101.4(h))

• %DV calculation and its footnote

(1) When calculating %DV, total fat, saturated fat, cholesterol, sodium, potassium, total carbohydrates, and dietary fiber may be calculated using the values on the supplement facts, and all other ingredients must be calculated using the values before modification. (21 CFR 101.36(b)(2)(iii)(B))

(2) The %DV is expressed to the nearest 1% increment. When the amount of a dietary ingredient is so small (but above the threshold value of 0) that the %DV would be zero when rounded, the %DV should be declared by using the terms “less than 1%” or “<1%” (e.g., a product containing 1 g of total carbohydrates would list %DV as “less than 1%” or “<1%”). (21 CFR 101.36(b)(2)(iii)(C))

(3) If total fat, saturated fat, total carbohydrates, dietary fiber, protein, or added sugars are indicated, the %DV values for these ingredients are marked with a specific symbol in conjunction with the footnote “Percent Daily Values are based on a 2,000 (or 1,000) calorie diet. “ (21 CFR 101.36(b)(2)(iii)(D))

(4) If a dietary ingredient without RDIs/DRVs is indicated, it is described in a footnote “Daily Value not established”. (21 CFR 101.36(b)(2)(iii)(F))

Conclusion

The format of the label is not limited to the given sample, it can be adjusted according to the size of the food package and the different contents, as well as the font size and line thickness. The details need to be further referred to the regulations. If you have any questions or need any help about US food labeling, please feel free to contact us at service@hfoushi.com.