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No addded sugar declaration on labels (products with HONEY)

![no-added-sugar|690x460](upload://lGup8jiKRwK6OwAGUatlTyoRtGv.jpeg)

Hello All,
I want to produce snack bars with honey.
Can I say "no added sugar" on my labels?

Legislation says that;
### WITH NO ADDED SUGARS

**A claim stating that sugars have not been added to a food, and any claim likely to have the same meaning for the consumer, may only be made where the product does not contain any added mono- or disaccharides or any other food used for its sweetening properties. If sugars are naturally present in the food, the following indication should also appear on the label: 'CONTAINS NATURALLY OCCURRING SUGARS**'.

( source: EFSA )

Is HONEY considered as "food used for its sweetening properties" ?
If yes , why DATES are NOT considered as "food used for its sweetening properties" ?

I assume, writing NO ADDED SUGAR with the snack bars with honey is acceptable. What do you think? Please give me your comments

Thank you ,
Best
Fiona

asked by @fiona • 12/21/2022

Answers (10)

asked by @admin • 12/21/2022
4

Hi @Fiona

imo it depends on your target.

If you use honey as a sweetener or/and as a sugar replacement both its sweetness or bulking properties, you should not use NO ADDED SUGAR declaration on your label.

But if you it for its functional properties for a small amount like 1 -3 % yes it is ok your can label your food as NO ADDED SUGAR.

@admin • 12/21/2022
11

Dear @Roy Could you please share your opinion with us?

@admin • 12/21/2022
24

Fda said foods having no added sugar declaration can contain natural sugar as part of ingredient..In this case honey can pass this criteria.

@roy • 12/21/2022
3

so what is your comment for EFSA directive?

![image|690x147](upload://143uCKmuAnZYX9UkTeVbjxxG8pr.jpeg)

@admin • 12/21/2022
11

It just an alternative statement that does not violates FDA statement.

@roy • 12/21/2022
15

@Roy said in question #12907:
does not violates FDA statement

yes, it does not. also efsa policy seems more strict than fda policy for this issue.

and i understand that from below **sentence** efsa does not allow no added sugar declaration for foods contain honey for its sweetining or bulking properties.

***A claim stating that sugars have not been added to a food, and any claim likely to have the same meaning for the consumer, may only be made where the product does not contain any added mono- or disaccharides or any other food used for its sweetening properties***

https://food.ec.europa.eu/safety/labelling-and-nutrition/nutrition-and-health-claims/nutrition-claims_en

![image|690x142](upload://mQ3yLWgQR5tNALW0eesiUYaGHTF.png)

@admin • 12/21/2022
7

The fact is that you must show to competent authorities some valid reasons to demonstrate that your added honey is not for for sweetening purpose but for some others (i.e. rheology of the product). The same concept is applied to concentrated fruit juices (e.g. apple and grapes).

@pier.lorenzo.rol • 12/21/2022
25

good point. thanks @Pier_Lorenzo_Rol

@admin • 12/21/2022
4

I agree, so what is the difference betwenn added honey and added apple juice concrate ? Both are added for couple of reasons; taste and texture...

@fiona • 12/21/2022
24

Hello,

Here honey is considered as food used for its sweeting properties (if it's used to sweeten). Moreover the level of sweetness added can be too high to be solely for the purpose of giving structure to the product and this could mislead the infomation to the consumer.

@keziah • 12/21/2022