Total sugars is every free mono- and disaccharide in the food, whatever its origin. Added sugars is the subset that was put there during processing, plus sugars from syrups, honey and concentrated fruit or vegetable juices. The distinction is not about chemistry, because the molecules are often identical. It is about what happened to the food, which is why the same fruit can count as zero added sugar in one product and several grams in another.
Only one of the two has a Daily Value. Total sugars has none, because no authority has set a recommended total. Added sugars has a Daily Value of 50 g, based on a 2,000 calorie day.
The two lines, side by side
| Total Sugars | Added Sugars | |
|---|---|---|
| Regulatory definition | The "sum of all free mono- and disaccharides (such as glucose, fructose, lactose, and sucrose)" | Sugars "added during the processing of foods, or packaged as such," plus sugars from syrups and honey and from concentrated fruit or vegetable juices beyond what the same volume of 100 percent juice would contain |
| Where it lives | 21 CFR 101.9(c)(6)(ii) | 21 CFR 101.9(c)(6)(iii) |
| Includes sugar in milk, whole fruit and vegetables | Yes | No |
| Daily Value | None. No recommendation exists for total sugar intake | 50 g per day on a 2,000 calorie diet |
| How it appears on the panel | Its own line | Indented beneath, introduced by "Includes," to signal it is a portion of the total rather than an addition to it |
That last row causes a surprising amount of confusion. A yogurt listing 15 g total sugars and "Includes 7 g Added Sugars" contains 15 g of sugar in total, of which 7 g were added and 8 g came from the milk. The two numbers are not summed.
What counts as added, and what does not
| Counts as added sugar | Does not count as added sugar |
|---|---|
| Table sugar, sucrose, dextrose, glucose, fructose stirred into a product | Lactose naturally present in milk and plain yogurt |
| High-fructose corn syrup, brown rice syrup, agave, maple syrup, molasses | Fructose naturally present in whole fruit |
| Honey, including in products marketed as unrefined | Sugars naturally present in vegetables |
| Concentrated fruit or vegetable juice used as a sweetener, above what the equivalent volume of 100 percent juice would supply | 100 percent juice concentrate reconstituted and sold to consumers as juice |
| Jam, jelly or concentrated fruit juice used as an ingredient in something else | Fruit juice concentrate used for the fruit component of jams and preserves that meet the federal standard of identity |
The fourth row is the one the food industry has spent the most energy on. Sweetening a cereal bar with apple juice concentrate is, under the regulation, adding sugar. It has been a common way to move sugar off the ingredient list without moving it off the label, and the rule closed it.
Notice what the whole framework implies: the label is a record of manufacturing, not of metabolism. Your body does not distinguish the fructose in apple juice concentrate from the fructose in an apple. The label distinguishes them because the surrounding food, its fiber and how quickly you can eat a lot of it are what actually differ. We looked at that difference in SaladPower vs green juice.
What the words on the front of the package legally require
Front-of-pack sugar language is regulated separately from the Nutrition Facts panel, under 21 CFR 101.60(c), and the thresholds are stricter than most shoppers assume.
| Claim | What it legally requires |
|---|---|
| "Sugar free," "zero sugar," "no sugar," "sugarless," "without sugar," "trivial source of sugar" | All treated identically. Less than 0.5 g of sugars per reference amount customarily consumed and per labeled serving. The food must also be low calorie or reduced calorie, or else say plainly that it is not |
| "No added sugar," "no sugar added," "without added sugar" | Five conditions. No sugars or sugar-containing functional substitute added in processing or packaging; no ingredient containing added sugars such as jam, jelly or concentrated fruit juice; sugar content not raised by enzymes or similar means; the food it substitutes for normally does contain added sugar; and it must carry a statement that it is not low calorie or calorie reduced unless it qualifies, directing readers to the panel |
Two things fall out of this table. "Zero sugar" is not a marketing flourish with a loose meaning, it is the same legal standard as "sugar free" and it is set at half a gram. And "no added sugar" is a harder claim to make than it sounds, because a product only qualifies if the thing it replaces normally contains added sugar, and it has to disclose that it is not therefore a low calorie food.
The same fruit, four ways
This is the clearest way to see the rule working. Nothing changes about the sugar molecules. Everything changes about how the label treats them.
| Product | Total sugars | Added sugars | Why |
|---|---|---|---|
| A whole apple | Present | Zero | Naturally occurring in the fruit, and whole fruit is exempt by definition |
| 100 percent apple juice | Present, and higher per mouthful than the apple | Zero | Nothing was added. The fiber was removed, which the added sugars line does not measure |
| A granola bar sweetened with apple juice concentrate | Present | Counted | Concentrated juice used above the 100 percent juice equivalent is added sugar under the rule |
| Apple sauce with sugar stirred in | Present | Counted | Sucrose added during processing |
Row two is the honest limitation of the added sugars line, and it is worth saying out loud even though it is inconvenient for anyone selling a drink. A juice with no added sugar still delivers its sugar faster and with less fiber than the fruit it came from. Added sugars is a useful number. It is not a complete description of a food.
The allulose problem: when a label follows FDA guidance and is still sued
The most instructive thing happening in sugar labeling right now is a fight over a sweetener that behaves nothing like sugar and is legally treated as one.
Allulose is a monosaccharide found naturally in figs and molasses. It is barely metabolized, contributes roughly 0.4 calories per gram, and does not produce a meaningful glycemic response. In October 2020, the FDA issued final guidance saying it intended to exercise enforcement discretion for excluding allulose from both Total Sugars and Added Sugars, pending a rulemaking. Manufacturers built products on that guidance.
The rulemaking never came. And on July 27, 2026, the Seventh Circuit Court of Appeals revived a consumer class action in Franco v. Chobani, LLC, No. 25-2087, over a yogurt labeled "Zero Sugar" containing 4 g of allulose per serving, well above the 0.5 g threshold. The court reasoned that the regulation defining total sugars covers all monosaccharides, and allulose is a monosaccharide. The FDA filed a brief in the case agreeing with that reading, against the position its own guidance had created.
The pivotal holding is one that anyone who reads food labels should understand:
| What the 2020 guidance was | What it was not |
|---|---|
| A statement that FDA did not intend to enforce the rule against allulose exclusions | A ruling that such labels are lawful |
| FDA's stated current thinking, which the agency itself describes as recommendations | A legally enforceable responsibility. FDA guidance documents say so on their face |
| Explicitly temporary, pending a rulemaking that has not happened | A shield against consumer claims brought under state law |
Because the court found allulose is a sugar under the federal rule, federal law does not block state consumer protection claims, which opens the door to class actions in multiple states. Several other brands have received similar complaints since. The case itself is not over: it returns to the trial court, and the company has remaining arguments, including that FDA reviewed its specific label.
The reasoning also reaches further than one sweetener. Tagatose, another rare sugar, is also a monosaccharide and received the same enforcement-discretion treatment in late 2025, which puts products using it in the same position.
There is a fair argument on the other side, and it deserves stating. If the purpose of a sugar-free label is to tell someone managing blood sugar that a product will not spike them, allulose delivers exactly that, and treating it as sugar may push manufacturers toward artificial sweeteners instead. That is a reasonable policy view. It is simply not what the current regulation says, and the gap between the two is the whole story.
How the label treats every common sweetener
| Sweetener | Counts in Total Sugars | Counts in Added Sugars | Note |
|---|---|---|---|
| Sucrose, glucose, fructose, dextrose | Yes | Yes | The straightforward case |
| High-fructose corn syrup | Yes | Yes | |
| Honey, maple syrup, agave, molasses | Yes | Yes | Named in the regulation. Being unrefined changes nothing |
| Concentrated fruit or vegetable juice used to sweeten | Yes | Yes, above the 100 percent juice equivalent | The loophole the rule closed |
| Sugar in whole fruit, vegetables and milk | Yes | No | Naturally occurring and exempt |
| Allulose | Legally yes, excluded in practice under 2020 enforcement discretion | Same | The subject of the litigation above. Enforcement discretion is not the same as lawful |
| Tagatose | Same position as allulose | Same | Enforcement discretion granted late 2025 |
| Sugar alcohols: erythritol, xylitol, maltitol, sorbitol | No | No | Polyols, not mono- or disaccharides. Counted in Total Carbohydrate and may be declared on their own line |
| Stevia (steviol glycosides), monk fruit, sucralose, aspartame, acesulfame potassium | No | No | Not sugars at all. They contribute sweetness without carbohydrate |
How much added sugar is too much
The Dietary Guidelines for Americans recommend limiting calories from added sugars to less than 10 percent of total calories per day, which on a 2,000 calorie diet is 200 calories, or the 50 g Daily Value. FDA offers a quick reading rule for any single product:
| Percent DV for added sugars | Reading |
|---|---|
| 5 percent or less | A low source of added sugars |
| 20 percent or more | A high source of added sugars |
For most people in the United States the main sources of added sugars are sugar-sweetened beverages, baked goods, desserts and sweets, in that order. Which means the highest-leverage change is usually one category rather than a general effort to eat less sugar. Related: how to eat less ultra-processed food without cooking more.
Where SaladPower sits, and the question we get most
The most common objection to our product is the total sugars figure, so here is the panel and the reason behind it.
| Line | Per 8 oz pouch | What it means here |
|---|---|---|
| Total sugars | 11 g | All of it naturally occurring in the six whole ingredients: carrot, spinach, apple, kale, broccoli and lemon |
| Added sugars | 0 g | Nothing is added in processing, and no concentrated juice is used as a sweetener |
| Total carbohydrate | 21 g | |
| Fiber | 5 g, 18% DV | Retained, which is the difference between this and a juice |
| Calories | 90 |
The distinction that matters for the zero on that added sugars line is the one in the table further up: our apple and lemon go in as whole produce, not as concentrate used to sweeten. Had we used concentrate as a sweetener, the same sugar would be counted as added.
What we will not claim is that 11 g of naturally occurring sugar is nothing. It is real sugar and it is on the label, which is exactly where the fourth row of the four-ways table applies to us as much as to anyone: the fiber is the reason it behaves differently from juice, not the origin of the sugar. The longer version is in does SaladPower have added sugar, and the processing question is covered in what counts as ultra-processed food and are smoothies and blended foods ultra-processed.
Our point of view
Everything above is regulation. Here is where we stand.
The allulose case is, underneath the law, an argument about how to make engineered sweetness legible on a label. It is a real argument with reasonable people on both sides. We do not have a stake in it, because we do not engineer sweetness. The 11 g in a pouch is the sugar that was already in the carrot, the spinach, the apple, the kale, the broccoli and the lemon, and it arrives the way it arrived in the plant, alongside the fiber, vitamin A, vitamin C, iron and potassium that grew with it.
That is our position and it does not move with the news cycle. We think it is always better to eat real food. A whole vegetable delivers its nutrients together with the fiber and the compounds they occur with, and we believe the bioavailability of nutrients in real produce is unbeatable. A label can count grams. It cannot see what those grams arrived with, which is the lesson of the four-ways table above.
So our answer to nearly every question in this category is the same. Eat the vegetable. If eating it is the part that keeps not happening, drink it. Drink Your Vegetables.®
Frequently asked questions
What is the difference between total sugar and added sugar?
Total sugars is every free mono- and disaccharide in the food, including sugar naturally present in milk, fruit and vegetables. Added sugars is the portion put in during processing, plus sugars from syrups, honey and concentrated fruit or vegetable juices used as sweeteners. Total sugars has no Daily Value. Added sugars has one, at 50 g per day.
Do I add the added sugars number to the total sugars number?
No. Added sugars is a subset of total sugars, which is why the panel introduces it with the word "Includes." A product showing 15 g total sugars and 7 g added sugars contains 15 g of sugar altogether, 7 of which were added.
Does fruit sugar count as added sugar?
Not in whole fruit, and not in 100 percent juice sold as juice. It does count when concentrated fruit juice is used to sweeten something else, above what the same volume of 100 percent juice would have contributed. That rule exists because sweetening with juice concentrate was a common way to keep sugar off the ingredient list.
Is allulose sugar?
Chemically it is a monosaccharide, so under the federal definition of total sugars it is a sugar, even though the body barely metabolizes it and it produces little glycemic response. FDA said in 2020 that it would not enforce against excluding allulose from the label, but in July 2026 the Seventh Circuit held in Franco v. Chobani that this was a decision not to enforce rather than a ruling that such labels are lawful, so it does not block consumer lawsuits under state law.
What does "zero sugar" legally mean?
Less than 0.5 g of sugars per reference amount customarily consumed and per labeled serving. "Zero sugar," "sugar free," "no sugar," "sugarless" and "without sugar" are all held to that identical standard under 21 CFR 101.60(c). The product must also be low or reduced calorie, or state plainly that it is not.
Sources
- U.S. Food and Drug Administration. Added Sugars on the Nutrition Facts Label. Definitions, the 50 g Daily Value, the 5 percent and 20 percent reading rule, and the main dietary sources. Content current as of March 4, 2026. Read September 10, 2026.
- 21 CFR 101.9(c)(6)(ii) and (iii), nutrition labeling of food, via the Electronic Code of Federal Regulations. Source of the total sugars and added sugars definitions quoted above. Read September 10, 2026.
- 21 CFR 101.60(c), nutrient content claims for the calorie content of foods, via the Electronic Code of Federal Regulations. Source of the "sugar free," "zero sugar" and "no added sugar" conditions. Read September 10, 2026.
- U.S. Food and Drug Administration. Guidance for Industry: The Declaration of Allulose and Calories from Allulose on Nutrition and Supplement Facts Labels. Final guidance, October 2020, Docket FDA-2019-D-0725. Source of the enforcement discretion position and FDA's statement that guidance documents do not establish legally enforceable responsibilities. Read September 10, 2026.
- Franco v. Chobani, LLC, No. 25-2087 (7th Cir., July 27, 2026), as reported in Foster Garvey, "The Allulose 'Zero Sugar' Ruling and Why It Matters for the Food and Beverage Industry" (September 8, 2026), and Food Dive, "Zero-sugar labels take center stage in more food class action lawsuits." Read September 10, 2026.
- Dietary Guidelines for Americans, 2025-2030. realfood.gov
- SaladPower Nutrition Facts panel, per 8 oz pouch.
These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure or prevent any disease.
