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Dairy Facts 2016

IDFA Analyzes New FDA Guidance on Nutrition Facts, RACCs

Mar 07, 2018

The Food and Drug Administration published five new guidance documents last week that provide additional information on the updated Nutrition Facts label and Reference Amounts Customarily Consumed (RACCs). The documents provide clarifications for dairy products companies that are preparing to comply with the updated nutrition labeling requirements by the January 1, 2020, deadline.

While no document solely addressed dairy products, three are of interest to dairy processors.

  • One guidance provided additional details on the data companies must provide when petitioning FDA to add a substance to the definition of dietary fiber.
  • Another gave examples of foods and beverages that would be included in each category of Reference Amounts Customarily Consumed (RACC).
  • The third document provided guidance for small businesses on several topics related to the Nutrition Facts label and RACCs. According to Michelle Matto, R.D.N., IDFA’s consultant on nutrition and labeling, this document is a good reference for companies of all sizes.

Dietary Fiber

The updated Nutrition Facts label uses a definition for dietary fiber that requires a non-digestible carbohydrate to be either naturally occurring in plant-based food or, if added, to provide a health benefit. The original regulations regarding dietary fiber labeling identified seven substances that, when added to foods, would meet this requirement. Companies can submit petitions asking FDA to allow additional substances to be considered dietary fiber.

The guidance, “Scientific Evaluation of the Evidence on the Beneficial Physiological Effects of Isolated or Synthetic Non-Digestible Carbohydrates Submitted as a Citizen Petition,” provided further information about the requirements for proving that a carbohydrate has a health benefit. The guidance also discusses health outcomes and strength of science for nutrition studies to assist petitioners with preparing data for submission to FDA. This information may be useful for companies that are currently using added, non-digestible carbohydrates that are not considered dietary fiber under the new definition, such as the ingredient inulin.


RACCs serve as the basis for the serving size identified in each Nutrition Facts label. They also are the basis for determining whether a product must be labeled as a single serving or with dual column labeling. Categories exist for a number of dairy products, including cheese, grated cheese, cottage cheese, milk, shakes, yogurt and ice cream.

The guidance provided additional examples of beverages to help determine the RACC for each. Milk and milk-based beverages, including those beverages where milk or milk-derived ingredients serve as the major component when prepared for consumption, will have a RACC of 240 milliliters (mL), which is approximately one cup. The category of “juices, nectars, fruit drinks” includes any noncarbonated drinks containing any amount of fruit juice or nectar, such as lemonade, and would also have a RACC of 240 mL. All other noncarbonated beverages and sweetened coffee or tea beverages would have a larger RACC, of 360 mL, about 12 fluid ounces.

Small Entity Compliance Guide

The small entity compliance guidance covers numerous topics small companies would encounter as they seek to comply with the Nutrition Facts label. The question-and-answer section, which covers single-serving containers, dual-column labeling and ways to determine serving sizes, could be useful to larger companies, as well.

Other Guidance Documents

Two additional documents provide clarifying language regarding the added sugar labeling for honey, maple syrup and cranberry products and specified the more labeling requirements for honey and honey products.

Members may contact Michelle Matto, R.D.N., IDFA nutrition and labeling consultant, at

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