FDA’s 2016 dietary fiber regulations went into effect in July 2020. The Daily Value of fiber increased to 28g per day. However, “In the U.S., no analytical method truly measures fiber, but rather measures non-digestible carbohydrate (NDC),” explained David Plank, Senior Research Fellow, Univ. of Minnesota. Plank delved into the topic during his presentation titled “Labeling Fiber & Sugar: Maximizing Clean Label Advantages, Minimizing Class Action and Recall Risk” at Global Food Forums’ 2022 Clean Label Conference.
Non-Digestible Carbohydrates as Dietary Fiber
Insoluble NDC contains zero calories per gram. Soluble NDC contains about two calories per gram, and digestible carbohydrates four calories. The new definition of dietary fiber corresponds to the Codex definition, said Plank. Dietary fibers are non-digestible soluble and insoluble carbohydrates with three or more monomeric units and lignins, either intrinsic and intact or isolated or synthetic. Intrinsic and intact fibers are self-determined by the food manufacturer, while FDA determines isolated or synthetic fibers based on a Citizen Petition. (See chart “Examples of Intrinsic and Intact Dietary Fiber.”)
The requirements for Intrinsic and Intact Dietary Fiber are: 1) the fiber originates and is included wholly within a food and that no relevant components have been removed or destroyed; and 2) that the U.S. population must traditionally consume the dietary fiber.
Examples of intrinsic and intact fibers include those from vegetables, whole grains, fruits, nuts and cereal bran. The category does not include sugar cane fiber, apple fiber and bleached oat hulls, because significant dietary components have been removed.
Isolated or synthetic NDC must demonstrate at least one physiological benefit to health, such as lower blood pressure, reduced glycemic response, weight loss or laxation, before they can be included as dietary fiber. Certain fibers already had health claims, such as beta-glucan, psyllium husk, cellulose and guar gum, were approved with the rule. Examples of fibers approved through the citizen petition include mixed plant cell wall fibers, alginate, inulin and high-amylose starch. Polydextrose is unique, because it has a caloric value of 1 kcal/gram. Recent additions include glucomannan and acacia gum.
“Your product must be analyzed by an official method such as AOAC 2011.25 or AOAC 2017.16 for soluble and insoluble NDC. Using a database is not acceptable,” said Plank. Through record keeping, a company must subtract the amount of recorded FDA-approved dietary fiber from the total amount of NDC analyzed. There are various approved AOAC methods, but the newer, more physiological methods will provide safer data from a labeling viewpoint.
Delineating Sweeteners and Sweet Fiber Ingredients
When measuring total dietary fiber in resistant starches, the older AOAC 991.43 (boiling water bath) method delivers significantly higher results than the newer AOAC 2009.01, a more physiological method. The latest method, AOAC 2017.16, is the most physiological; most closely simulates consumer digestion; and best correlates to human glycemic response. Plank reminded the audience that dietary fiber could be lost during food processing by heat, moisture, acid, shear, Maillard reactions and enzymes.
Recordkeeping is essential, and records must be maintained for a minimum of two years. To reconcile your data, you must first analyze for NDC and compare results to records for added dietary fiber. You can label all analyzed NDC as dietary fiber if they are equal. If not, you should only label analyzed NDC as dietary fiber.
Total grams of carbohydrates is a calculation of 100 minus the grams of protein, fat, moisture and ash. When calculating calories, use the Atwater Factors and, per the new regulations, use two times soluble NDC and four times insoluble NDC.
From a clean label perspective, the ultimate sugar label declaration is 0g of added sugar. Many manufacturers use a combination of sugar alcohols and high-intensity sweeteners. Below are some special situations.
- FDA has assigned alternative calories to all sugar alcohols. To make a sugar claim, you must list the total grams of sugar alcohol. Note that sugar alcohols may interfere with labeling sugars, and gas chromatography is the safest analytical method.
- Allulose has 0.4 calories per gram and is unique in that it is not included in total or added sugars, but must be included in total carbohydrates.
- Grain syrup sweeteners must list sugars as added sugars, and enzymes must be labeled unless inactivated.
- When using fruit or vegetable extracts, if the sugar added exceeds the content of the whole fruit, as in fruit concentrates and powders, the sugar must be labeled as added sugars.
Due diligence to detail in labeling fiber and sugar will minimize the risk of recall, FDA enforcement action or class action lawsuit.
“Labeling Fiber & Sugar: Maximizing Clean Label Advantages, Minimizing Class Action and Recall Risk,” David Plank, Managing Principal, WRSS Food & Nutrition Insights/Senior Research Fellow, Department of Food Science and Nutrition, University of Minnesota
To view a pdf of this presentation, go to Labeling Fiber & Sugar: Maximizing Advantages, Minimizing Risk in Global Food Forums’ R&D Academy.