Limitations of Nutrition Facts Labels

Applications of Nutrition Data

Nutrition Facts labels are intended to allow consumers to make informed food choices, and to easily compare products. They were never intended as the source of nutrition data for recipe/formula analysis.

This article describes why Nutrition Facts labels are not adequate for recipe/formula nutrition analysis, where multiple ingredients are combined to calculate nutrition values for a finished product.

Good Nutrition Data

Here are the characteristics of good nutrition data for recipe/formula nutrition analysis.

  • Nutrition values should be for a 100g sample of the product. This is the standard for reporting nutrition data.
  • Nutrient values should be non-rounded.
  • Water content should be reported. This is important to account for water loss during cooking or processing.
  • Total nutrient weight for a 100g sample should equal 100g. Deviations from 100g indicate incomplete nutrition data. See the article Nutrient Deviation for details.
    • If the nutrition information reported is incomplete, the nutrition analysis of any recipe containing that ingredient will also be incomplete.
    • Large deviations are most often caused by unreported water and ash.
  • See the article Collecting Nutrition Data for more information.

Limitations of Nutrition Facts

Nutrition Facts labels are an inadequate source of nutrition information for recipe/formula analysis for the following reasons:

  • The values are rounded to make them easier for the consumer to read. This is a built-in inaccuracy.

    Here are US rounding rules.

    Here are Canadian rounding rules.

  • The sample sizes are often very small. This causes some nutrients to be listed as 0 (due to rounding), when they are actually present.
  • Not all of the nutrients are reported. This causes the total nutrient weight to deviate from the serving size.
  • Water content is not reported.

Recipes/Formulas

The nutrition for recipes or formulas is calculated by combining the nutrition from each of the ingredients. Using rounded ingredient nutrition values can significantly affect recipe nutrition accuracy.

  • Combining ingredients can have the effect of adding roundoff errors.
  • Scaling ingredients can have the effect of multiplying roundoff errors, especially if the reported nutrition data is for a very small serving size.
  • Nutrition values listed as zero may actually be non-zero, but round to zero for labelling purposes. When several of these rounded values are added the total will be zero, but the non-rounded totals might be significantly more than zero.

example: Adding roundoff errors - values that round to 0

You have a recipe with 9 ingredients, 4 of which each have .4g Added Sugar from sub-ingredients.

US rounding rules specify that Added Sugar values less than .5g are listed as 0g.

If you use the rounded values for your recipe, the Nutrition Facts for your product will list 0g Added Sugar.

However, if you use the non-rounded values, your product will actually have 1.6g, which will round to 2g Added Sugar on your Nutrition Facts label.

Note: The same effect can happen with rounded non-zero values.

example: Multiplying roundoff errors

You have Nutrition Facts with a serving size of 3g for an ingredient. Most of the nutrient values on the label list 0g (because the serving size is so small, and the values are rounded).

However, a serving of your product contains 7g of the ingredient. This means that even though the 3g values round to 0g, the 7g values might not.

In addition, your product might contain other ingredients that contribute those same nutrients, so your totals for those nutrients might be inaccurate.

Using the rounded values can have the following consequences.

  • Your product will be misbranded, and you will be open to FDA sanctions.
  • Your product will be misbranded, and you will be open to consumer litigation.
  • You will lose consumer confidence because consumers will notice that your ingredients list several instances of sugar, but your label indicates 0g Added Sugar.

Exemptions from Labeling

There are 2 classes of exemptions from Nutrition Facts labeling

  • Products that have very low volume sales or very low dollar sales, provided the product label makes no nutrition claims.
  • Products that have insignificant amounts of the nutrients listed on the Nutrition Facts label, provided the product label makes no nutrition claims.
    • "Insignificant amounts" means values that would be listed on the label as 0.
    • For Carbohydrates, Dietary Fiber and Protein, "insignificant amounts" means an amount that would be listed as <1g on the label.

While these products might be exempt from labeling for retail sale, nutrition data is still needed for recipe analysis.

As described above, nutrients from an exempt product might combine with nutrients from other ingredients to affect the final product label.

Proprietary Nutrition Data

Many manufacturers consider their product formulas as trade secrets. The FDA labeling regulations take this into account in several ways.

  • Many spices and flavorings can be listed on the Ingredient List simply as "spices", "natural flavors" or "artificial flavors".
  • Ingredient Lists sort the ingredients by weight. However, ingredients present at less than 2% of the total can be listed in any order. Manufacturers can use this to obscure the proportions of ingredients.

Even though it is sometimes possible to "reverse engineer" a formula from detailed nutrition data, the above factors frequently make this impossible.

We consider it counter-productive to refuse to share detailed nutrition data.

  • Customers using the item as an ingredient in their product are prevented from creating the Nutrition Facts labels they need to sell their products.
  • Manufacturers can always require a customer to sign a non-disclosure agreement to receive detailed nutrition data.
  • A determined competitor can easily buy your product and send it to a lab. They get a detailed analysis for hundreds of dollars. This is insignificant in most industries.