A Food Labeling Guide: Appendix B - Relative (or Comparative) Claims ΓΈ Calorie Counter
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A Food Labeling Guide: Appendix B - Relative (or Comparative) Claims

A Food Labeling Guide

Relative (or Comparative) Claims


Accompanying Information

For all relative claims, percent (or fraction) of change and identity of reference food must be declared in immediate proximity to the most prominent claim. Quantitative comparison of the amount of the nutrient in the product per labeled serving with that in reference food must be declared on information panel.

For "Light" claims: Generally, percentage reduction for both fat and calories must be stated. An exception is that percentage reduction need not be specified for "low-fat" products. Quantitative comparisons must be stated for both fat and calories.

For claims characterizing the level of antioxidant nutrients in a food:
  • An RDI must be established for each of the nutrients that are the subject of the claim
  • Each nutrient must have existing scientific evidence of antioxidant activity
  • The level of each nutrient must be sufficient to meet the definition for "high," "good source," or "high potency" in 21 CFR 101.54(b),(c), or (e)
Beta-carotene may be the subject of an antioxidant claim when the level of vitamin A present as beta-carotene in the food is sufficient to qualify for the claim.


Reference Food

"Light" or "Lite"
  • A food representative of the type of food bearing the claim (e.g., average value of top three brands or representative value from valid data base)
  • Similar food (e.g., potato chips for potato chips)
  • Not low-calorie and low-fat (except light-sodium foods which must be low-calorie & low-fat)
"Reduced" and "Added"
(or Fortified" and "Enriched")
  • An established regular product or average representative product
  • Similar food
"More" and "Less"
(or "Fewer")
  • An established regular product or average representative product
  • A dissimilar food in the same product category which may be generally substituted for the labeled food (e.g., potato chips for pretzels) or a similar food


Other Nutrient Content Claims

"Lean" On seafood or game meat that contains less than 10g total fat, 4.5g or less saturated fat, and less than 95mg cholesterol per reference amount and per 100g (for meals & main dishes, meets criteria per 100g and per labeled serving).
"Extra Lean" On seafood or game meat that contains less than 5g total fat, less than 2g saturated fat and less than 95mg cholesterol per reference amount and per 100g (for meals and main dishes, meets criteria per 100g and per labeled serving).
High Potency May be used on foods to describe individual vitamins or minerals that are present at 100% or more of the RDI per reference amount or on a multi-ingredient food product that contains 100% or more of the RDI for at least 2/3 of the vitamins and minerals with DV's and that are present in the product at 2% or more of the RDI (e.g., "High potency multivitamin, multimineral dietary supplement tablets").
"High", "Rich In", or
"Excellent Source Of"
Contains 20% or more of the Daily Value (DV) to describe protein, vitamins, minerals, dietary fiber, or potassium per reference amount. May be used on meals or main dishes to indicate that product contains a food that meets definition. May not be used for total carbohydrate.
"Good Source of",
"Contains" or "Provides"
10%-19% of the DV per reference amount. These terms may be used on meals or main dishes to indicate that product contains a food that meets definition. May not be used for total carbohydrate.
"More", "Added",
"Extra", or "Plus"
10% or more of the DV per reference amount. May only be used for vitamins, minerals, protein, dietary fiber, and potassium.
"Modified" May be used in statement of identity that bears a relative claim (e.g., "Modified Fat Cheese Cake, contains 35% Less Fat than our Regular Cheese Cake.")
Any Fiber Claim If food is not low in total fat, must state total fat in conjunction with claim such as "More Fiber".


Implied Claims

  • Claims about a food or ingredient that suggests that the nutrient or ingredient are absent or present in a certain amount or claims about a food that suggests a food may be useful in maintaining healthy dietary practices and which are made with an explicit claim (e.g. "healthy, contains 3 grams of fat") are implied claims and are prohibited unless provided for in a regulation by FDA. In addition, the Agency has devised a petition system whereby specific additional claims may be considered.
  • Claims that a food contains or is made with an ingredient that is known to contain a particular nutrient may be made if product is "Low" in or a "Good Source" of the nutrient associated with the claim (e.g. "good source of oat bran").
  • Equivalence claims: "contains as much [nutrient] as a [food]" may be made if both reference food and labeled food are a "Good Source" of a nutrient on a per serving basis. (e.g. "Contains as much vitamin C as an 8 ounce glass of orange juice").
  • The following label statements are generally not considered implied claims unless they are made in a nutrition context: 1) avoidance claims for religious, food intolerance, or other non-nutrition related reasons (e.g. "100% milk free"); 2) statements about non-nutritive substances (e.g. "no artificial colors"); 3) added value statements (e.g. "made with real butter"); 4) statements of identity (e.g. "corn oil" or "corn oil margarine"); and 5) special dietary statements made in compliance with a specific Part 105 provision.

Claims on Foods for Infants and Children Less than 2 Years of Age

Nutrient content claims are not permitted on foods intended specifically for infants and children less than 2 years of age except:
  • Claims describing the percentage of vitamins and minerals in a food in relation to a daily value.
  • Claims on infant formulas provided for in Part 107.
  • The terms "Unsweetened" and "Unsalted" as taste claims.
  • "Sugar Free" and "No Added Sugar" claims on dietary supplements only.

Terms Covered That Are Not Nutrient Content Claims

"Fresh" A raw food that has not been frozen, heat processed, or otherwise preserved
"Fresh Frozen" Food was quickly frozen while still fresh


A Food Labeling Guide



Food and Drug Administration Center for Food Safety and Applied Nutrition
A Food Labeling Guide, September 1994 (Editorial revisions June, 1999)

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