Some ingredients contain mono- and disaccharides (DP1 and DP2 (one and two degrees of polymerization)) that are created through processes such as hydrolysis. Do the mono and disaccharide portions of ingredients that are created through hydrolysis need to be declared as added sugars on the label?

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In the preamble to the final Nutrition Facts label rule (81 FR 33742 at 33831), we said that,
other than sugar syrup types of products where the sugars are specifically and purposely
produced via hydrolysis, we do not have information suggesting that sugars produced
through incidental hydrolysis of complex carbohydrates results in significant increase in the
sugar content of foods. Sugars which are produced through incidental hydrolysis would be
captured in the total sugars declaration, but we did not have any comments or other
information suggesting that these sugars should be captured under the added sugars
declaration. Therefore, they are not included in our definition of added sugars and would not
be declared as added sugars on the label. We also explained our position that if a
manufacturer purposely employs a hydrolysis step as part of a food manufacturing process to
increase the sugar content of a food product (e.g. enzymatic hydrolysis of corn starch to
make corn syrup in the same facility as part of the cookie-making process), we would
consider the sugar generated from the hydrolysis step to be added sugars, since hydrolysis
was purposely used by the manufacturer to increase the sugar content of the product (81 FR
337242 at 33832).
In the preamble to the Nutrition Facts label final rule (81 FR 33742 at 33835), we also said
that, in determining which sugars should be included in the definition of added sugars, we
have considered the presence of added sugars as a component of dietary intake and whether it
is consistent with the concept of empty calories, as discussed in the 2015 DGAC Report.
Manufacturers may purposely employ methods, such as hydrolysis for a number of reasons,
some of which result in an ingredient containing mono- and disaccharides with DP1 and
DP2. Ingredients such as maltodextrin and corn syrup solids are hydrolyzed to achieve
various degrees of dextrose equivalence (DE). The higher the DE, the lower the degree of
polymerization, and the sweeter the ingredient becomes. Maltodextrins (21 CFR 184.144)
are ingredients with a DE less than 20, and corn syrup solids (21 CFR 168.121) are
ingredients with a DE of 20 or higher. Depending on the manufacturing process, different
maltodextrin and corn syrup solids will have different DE and different amounts of mono and
disaccharides. Although maltodextrins are not used primarily for sweetening purposes,
depending on the DE, some can contain 8-9% mono and disaccharides and can contribute to
sweetness. We also understand that the hydrolysis process to manufacture maltodextrin and
corn syrup solids are controlled so that the desired DE can be consistently achieved. This
indicates that some maltodextrins and corn syrup solids are manufactured purposely to
contain certain levels of mono- and disaccharides.
If a serving of a product contains less than 0.5 grams of added sugars from maltodextrins,
corn syrup solids, or another ingredient made with a hydrolysis step, we would consider the
presence of this low amount of mono- and disaccharides to be an insignificant amount
towards the empty calorie contribution from the added sugars content of the diet. The added
sugars content may be expressed as zero on the label at these low levels. When the monoand
disaccharides are present in such small amounts that they do not contribute to the
sweetness of a product, we would anticipate that the amount of mono- and disaccharides
would be so low that they would not contribute to an added sugars declaration (e.g. there
would be less than 0.5 grams of mono- and disaccharides contributed by the ingredient).
Such small amounts of mono- and disaccharides would also not contribute meaningful
amounts of calories to the diet.
Ingredients, such as maltodextrins, are used in many food products and may contribute more
than 0.5 grams per serving in some foods. When maltodextrins are intentionally created
through hydrolysis in amounts of greater than 0.5 grams per serving, their contribution to the
overall diet would be consistent with the concept of empty calories, and when present, must
be declared as added sugars on the label. Similarly, when mono- and disaccharides with DP1
and DP2 are created through hydrolysis and are present in other ingredients in amounts of 0.5
grams or greater, those mono- and disaccharides contribute empty calories to foods and must
also be declared as added sugars on the label (21 CFR 101.9(c)(9)(iii)).