Do sugars present in a sweet fermented beverage after fermentation need to be declared as total or added sugars on the label?

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If the fermented beverage contains only sugars that meet our definition of added sugars (e.g.
table sugar), then the amount of sugars present in a serving of the product after fermentation
must be declared as both total and added sugars (21 CFR 101.9(c)(6)(iii)).
If the fermented beverage contains both sugars that do and do not meet our definition of
added sugars, you can determine the amount of total sugars in the finished food analytically.
You have the following options related to the added sugars declaration:

  1. Determine a reasonable approximation of the amount of added sugars in the finished
    product and make and keep records of all relevant scientific data and information you
    relied upon that demonstrates the amount of added sugars in the food after
    fermentation and a narrative explaining why the data and information are sufficient to
    demonstrate the amount of added sugars declared in the finished food, provided the
    data and information used is specific to the type of food that is subject to nonenzymatic
    browning and/or fermentation; or
  2. Declare the amount of added sugars added prior to fermentation and make and keep
    records to verify the amount. The amount of added sugars declared should not
    exceed the amount of total sugars on the label; or
  3. If you have no way to determine a reasonable approximation of the amount of added
    sugars in the finished food, but have reason to believe that a significant reduction of
    added sugars took place during fermentation, you may submit a petition, under 21
    CFR 10.30, to request an alternative means of compliance. The petition should
    provide scientific data or other information for why the amount of added sugars in a
    serving of the product is likely to have a significant reduction in added sugars
    compared to the amount added prior to fermentation. A significant reduction would
    be where reduction in added sugars after fermentation may be significant enough to
    impact the label declaration for added sugars by an amount that exceeds the
    reasonable deficiency acceptable within good manufacturing practice under §
    101.9(g)(6). In addition, the scientific data or other information should include the
    reason why you are unable to determine a reasonable approximation of the amount of
    added sugars in a serving of the finished product and a description of the process that
    you used to come to that conclusion.