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Volume 13, Number 11 - November 2013

Greetings from Food Label News. This November, we are filled with gratitude as we celebrate Food Consulting Company's 20th anniversary providing food labeling and regulatory guidance for our clients around the world. It's been a pleasure to bring you Food Label News (now in its 14th year) and see how engaging the Food Label Community on LinkedIn has become. In this issue, we discuss the confusion around counting calories, always a popular topic with consumers. We also begin an 8-part series on package claims for the U.S. and Canada – a popular topic for food labelers. Giving thanks for all our blessings.

In this issue you'll find:


"You did an excellent job on our Nutritional Information Guide - thank you!"

– Sharill Hanns

Calorie Counting Confusion

Package Claims: U.S. & Canada
An 8-part Series

Reader Q&A: Labeling Trace Ingredients

What's News in the Food Label Community


Karen C. Duester, President

Calorie Counting Confusion

The method for quantifying calories for Nutrition Facts labeling can be confusing to food labelers and consumers alike. There are five methods allowed for determining calories that can result in slightly different values.


General 4-4-9 factors – carbohydrate and protein each contribute 4 calories per gram, fat contributes 9 calories per gram


Adjusted 4-4-9 factors – insoluble fiber is subtracted from the carbohydrate total before multiplying by 4 (since insoluble fiber does not impact the calorie value of foods)


Specific Atwater factors


Other specific food factors approved by FDA


Bomb calorimetry

While the 4-4-9 method is allowable and generally used with laboratory analysis, it is the least accurate of the five. These "average" factors generally overstate calories because specific ingredients often contain fewer calories than the average factor would indicate. For example, dextrose (a carbohydrate) contains 3.4 calories per gram, not 4 calories per gram as the 4-4-9 method would indicate.

Food Consulting Company uses a database nutritional analysis with Atwater or other food factors for most ingredients and relies on an adjusted 4-4-9 calculation for those ingredients where specific food factors are not available. Over time we have found this to result in a more accurate (and lower) calorie value than the general 4-4-9 method.

The challenge for food labelers and customer service is when consumers attempt to validate calories using the 4-4-9 calculation shown in the optional footnote on the Nutrition Facts. As we know, values can vary depending upon the calorie determination method used. Customer service representatives must be trained to explain your method of calorie determination and confirm the accuracy of your labels.

What's News in the
Food Label Community


Changes coming for Nutrition Facts labels and serving sizes


"Natural" ... lawsuits, leaveners, rosemary extract, and more


New Qualified Health Claim links whole grains & type 2 diabetes


FDA Tweets! @FDAFood


Facts Up Front: use packaged or prepared values?


Using database analysis to determine nutrient values for a dehydrated product


Product naming for parmesan type bread with natural flavor but no parmesan cheese


Labeling for steviol glycosides in Canada

Connect with other food labelers on LinkedIn

Reader Favorites

Key Differences in Ingredient and Allergen labeling for U.S. & Canada


Search answers to food label questions

The "calories per gram" footnote for the Nutrition Facts label is always optional. You may wish to consider omitting this footnote to save label real estate and eliminate a potential customer service issue, especially when the calorie determination method you are using results in a different value than what the 4-4-9 method would yield. See a sample nutrition facts label with and without the optional footnote.

Package Claims: U.S. & Canada - An 8-Part Series

Label claims and statements are designed to capture consumers' attention and increase product sales, but developing compliant claims can be tricky. This 8-part series will help food labelers become familiar with allowable claims and how to position a product’s nutritional attributes to achieve marketing objectives.

In this series of articles, you will find a quick reference for: nutrient content claims, statements of fact, health claims, structure/function claims, and dietary guidance statements. Each month we will provide print-ready pages that overview what you need to know about making compliant label claims and statements. By the conclusion of the series, you will have a complete regulatory guide updated for 2013 for U.S. and Canadian package claims.

This month's installment includes the front cover, table of contents, and label claims and statements for conventional foods vs. dietary supplements, as well as disclosure statement requirements.

View/print Part 1 of the series.

Reader Q&A

Find answers to our readers' questions or send us your question for an upcoming issue.


We are using a tiny amount of tricalcium phosphate (~0.2%) in the production of one of our sugar products that we sell retail. The purpose of this ingredient is to aid in process flow. Do we need to list tricalcium phosphate on the finished product label?
R.L., California, Retail Food Sales


All retail products must list all ingredients that have a technical or functional effect in the finished product. If the tricalcium phosphate aids in the flow of the finished product, then it must be declared. Read more.

What matters in food labeling

Food Label News, now in its 14th year, is a monthly e-newsletter reaching over 8,000 subscribers around the world. We welcome your colleagues to subscribe for news and insights about food labels:


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