FDA gives a 20% leeway for accuracy on nutrition labels.

Jess__I__Can

The Third Group nutrients include calories, sugars, total fat, saturated fat, cholesterol, and sodium. However, for products (e.g., fruit drinks, juices, and confectioneries) with a sugars content of 90 percent or more of total carbohydrate, to prevent labeling anomalies due in part to rounding, FDA treats total carbohydrate as a Third Group nutrient instead of a Class II nutrient. For foods with label declarations of Third Group nutrients, the ratio between the amount obtained by laboratory analysis and the amount declared on the product label in the Nutrition Facts panel must be 120% or less, i.e., the label is considered to be out of compliance if the nutrient content of a composite of the product is greater than 20% above the value declared on the label. For example, if a laboratory analysis found 8 g of total fat/serving in a product that stated that it contained 6 g of total fat/serving, the ratio between the laboratory value and the label value would be (8 / 6) x 100 = 133%, and the product label would be considered to be out of compliance.

It appears that the 20% rule only applies to " products (e.g., fruit drinks, juices, and confectioneries) with a sugars content of 90 percent or more of total carbohydrate." What am I missing?

FIT_Goat

It also helps if you read what you cite:


Class I nutrients are the following only when added in fortified foods... otherwise they are class ii:

* vitamins
* minerals
* protein
* dietary fiber
* potassium

When a food product is FORTIFIED with one of the above... it must exist @ >100%


Class II nutrients (>80%):

* vitamins
* minerals
* protein
* total carbohydrate
* dietary fiber
* other carbohydrate
* polyunsaturated
* monounsaturated fat
* potassium

The Third Group (120% or less) nutrients include:

* calories
* sugars
* total fat
* saturated fat
* cholesterol
* sodium

Reasonable excesses of class I and II nutrients above labeled amounts and reasonable deficiencies of the Third Group nutrients are usually considered acceptable by the agency within good manufacturing practices.


So... since the majority of the calories come from items in class ii (and are calculated from them according to the rules I posted earlier), or from the third group, neither of which require 100% or more... (one of which is 80% or more... the other which is less than 120% but doesn't have a floor)... it is just blatantly false to claim the calories will always be higher than on the label.


Something like a protein powder must have 100% of the protein it claims to have. But calories is never in the 100%+ category.

Alice_in_VVonderland

I think this just reinforces the idea that eating out should be done as a rare treat, and not as an every day habit.

For someone counting close, running small deficits? Yep, that's about right. The error bars on restaurant food are gigantic. Ironically, your safest bet would be the value menus at large fast food chains, as their profit margins don't allow for as much overage and they have well-defined "idiot proof" food assembly lines.

Idiot proof? *snort* Puh-lease.

I've worked at McDonald's, Burger King, and Taco Bell. When the mayo gun malfunctions and everyone gets 50% more mayo for the day, nothing can be done about it. Or you're in a hurry and accidentally do a double pump of guacamole. Or you accidentally put extra nacho cheese on the wrong burrito. Or they put a pan of shredded cheese in front of you and tell you only to use a pinch on each item, but depending on the person a pinch could have 4 different weights.

I can walk into 4 different Burger Kings, order a Whopper with Cheese, and get 4 different burgers.

Edit: Heck, I can remember when I had to insist on going to the Jack in the Box clear across town, because the one closer to home INSISTED on putting mustard on a burger that wasn't supposed to have mustard. Even if I specifically ordered it without the mustard. (I realize mustard calories are negligible, but I'm using this as an example)

stealthq

I agree its helpful to KNOW there is a margin of error. However, to put a number on it that is not entirely accurate could causeThat person would be misunderstanding the numbers. The calories can be as much as 20% higher or lower.

That is also incorrect. The FDA specifically mandates a one-sided variance, meaning the actual numbers are almost always HIGHER than labelled, and almost never LOWER than labelled.

This is an intentional policy decision, designed to protect consumers from getting less than they believe they paid for.

Source?

http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/labelingnutrition/ucm063113.htm

From the above manual:

n order to evaluate the accuracy of nutrition label information against a standard for compliance purposes, FDA regulations define two nutrient classes (Class I and Class II) (21 CFR 101.9(g)(3)) and list a third group (Third Group) of nutrients (21 CFR 101.9(g)(5)). Class I nutrients are those added in fortified or fabricated foods. These nutrients are vitamins, minerals, protein, dietary fiber, or potassium. Class I nutrients must be present at 100% or more of the value declared on the label ; in other words, the nutrient content identified by the laboratory analysis must be at least equal to the label value. For example, if vitamin C is added in a fortified product and the label states that vitamin C is present at 10% Daily Value (DV), the laboratory value must equal at least 6 mg of vitamin C/serving (i.e., 10% of the 60 mg Reference Daily Intake (RDI) for vitamin C that is specified in 21 CFR 101.9(c)(8)(iv)). The ratio between a laboratory finding of 4.8 mg vitamin C/serving (i.e., 8% DV) and the label value of 10% DV would be calculated as follows:

(8% / 10%) x 100 = 80% or (4.8 mg / 6 mg) x 100 = 80%

and the label value would not be in compliance.

Class II nutrients are vitamins, minerals, protein, total carbohydrate, dietary fiber, other carbohydrate, polyunsaturated and monounsaturated fat, or potassium that occur naturally in a food product. Class II nutrients must be present at 80% or more of the value declared on the label. As an example: If vitamin C is a naturally occurring nutrient in a product, and the product declares 10% DV vitamin C (i.e., 6 mg/serving) on its label, then laboratory analysis must find at least 80% of the label value (80% of 6 mg or 4.8 mg vitamin C/serving) for the product to be in compliance.

The Third Group nutrients include calories, sugars, total fat, saturated fat, cholesterol, and sodium. However, for products (e.g., fruit drinks, juices, and confectioneries) with a sugars content of 90 percent or more of total carbohydrate, to prevent labeling anomalies due in part to rounding, FDA treats total carbohydrate as a Third Group nutrient instead of a Class II nutrient. For foods with label declarations of Third Group nutrients, the ratio between the amount obtained by laboratory analysis and the amount declared on the product label in the Nutrition Facts panel must be 120% or less, i.e., the label is considered to be out of compliance if the nutrient content of a composite of the product is greater than 20% above the value declared on the label. For example, if a laboratory analysis found 8 g of total fat/serving in a product that stated that it contained 6 g of total fat/serving, the ratio between the laboratory value and the label value would be (8 / 6) x 100 = 133%, and the product label would be considered to be out of compliance.

Reasonable excesses of class I and II nutrients above labeled amounts and reasonable deficiencies of the Third Group nutrients are usually considered acceptable by the agency within good manufacturing practices.

So, in summary:

1) Nutrients that are added to a product (i.e. 'fortified with vitamin C') must be present in at least the amount on the label.
2) Nutrients (vitamins, minerals, protein, total carbohydrate, dietary fiber, other carbohydrate, polyunsaturated and monounsaturated fat, or potassium) that are naturally found in the product must be present in at least 80% of the amount on the label.
3) Other naturally occurring nutrients (calories, sugars, total fat, saturated fat, cholesterol, and sodium) must be present in 120% or less of the amount on the label.

Unless I've misunderstood somewhere, that means you could have a product with less than 80% of the calories listed and be in perfect compliance if the sat. fat levels were low enough - there's no lower boundary on that from what I can see. Doubt that happens very often.

astronomicals

Nb4 40% deficit suggestion to counter inaccuracies...


that sad part is someone probably does this

Mr_Knight

.... it is just blatantly false to claim the calories will always be higher than on the label.

Believe what you want to believe.

Cheers.

FIT_Goat

.... it is just blatantly false to claim the calories will always be higher than on the label.

Believe what you want to believe.

Cheers.

I'll believe what the evidence supports. I asked you for a source that proved the calories would always be 100% or higher than was on the label. You provided a quote, from the government, that doesn't support that and, instead, supports and range of 80%-120% for unfortified foods (and apparently less than 80% if a food gets its calories primarily from saturated fat and is low enough compared to the label). In a specific case, say a protein powder, you would likely be correct. Since it is fortified and the vast majority of its calculated calories come from protein (which must be 100% or more), then the calories would likely always be confined to a range of 100% to 120%.

I do thank you for providing the link. I'd heard of the 20% thing often, and accepted it as reasonably likely to be true (knowing how much food varies, it makes sense that labels are allowed a margin for variation). I had never heard that it must be at least the label, which is why I asked for some supporting evidence. You didn't provide that, but you did help me understand a bit more about where the +/- 20% claim comes from and how it gets determined.

lemurcat12

I agree its helpful to KNOW there is a margin of error. However, to put a number on it that is not entirely accurate could causeThat person would be misunderstanding the numbers. The calories can be as much as 20% higher or lower.

That is also incorrect. The FDA specifically mandates a one-sided variance, meaning the actual numbers are almost always HIGHER than labelled, and almost never LOWER than labelled.

This is an intentional policy decision, designed to protect consumers from getting less than they believe they paid for.

Source?

Here's what seems to be the most relevant bit from the same CFR (21 CFR Sec. 101.9) that provides for the acceptable ways to measure calories:

(5) A food with a label declaration of calories, sugars, total fat, saturated fat, trans fat, cholesterol, or sodium shall be deemed to be misbranded under section 403(a) of the act if the nutrient content of the composite is greater than 20 percent in excess of the value for that nutrient declared on the label. Provided, That no regulatory action will be based on a determination of a nutrient value that falls above this level by a factor less than the variability generally recognized for the analytical method used in that food at the level involved.

Edit: to be clear, rather than intending to protect the consumer against getting too little of the property, it seems clear from the language of the regulation itself that the intent is to prevent underreporting of these things. The manufacturer would be safer to aim low.

lemurcat12

As a consumer, I honestly thought that companies like that paid to have those tests done. I mean, if you're in the business of food, you should be all up in the business of your food.

One problem is that even when products are manufactured largely by machine there are going to be slight differences.

As for eating out (back to the original topic, I guess), I typically go to restaurants that don't have calorie counts at all, so can't get worked up about the fact the calorie counts are imperfect. At a restaurant, how could they not be? And as for products, well, the issue with meat was discussed above. I'm always guessing about my meat calories, and yet it doesn't prevent weight loss. This seems not to be that big a deal.

jmv7117

All the more reason to eat whole plant based foods! So you know what is actually in them and what the nutrition is :laugh:

You don't read well do you? The variation in whole plant foods in equally high even when the scale weights are held constant. Even more, the nutrient density of natural foods is highly variable (age, ripeness when picked, handling, storage temps, method of preparation, etc.) all impact how much of eat nutrient remains and is bio-available. You are suffering from at least as much uncertainly as everyone else.

This is why even when actively losing weight, I did not get hung up on the calorie issue. Obviously the calories in 2 kg of apples is considerably higher than the on average 150 g apple I eat so whether it is 149 g or 151 g or slightly higher in calories than the database, those few extra calories are not going to make a huge difference in the big picture. Even if you religiously weigh out each and every morsel of food that goes into your mouth you can still be off by 20% or more. I do think being slightly off with whole foods is less problematic than it is with processed foods. Whether it is enough to affect weight loss is another issue.

auddii

It also helps if you read what you cite:


Class I nutrients are the following only when added in fortified foods... otherwise they are class ii:

* vitamins
* minerals
* protein
* dietary fiber
* potassium

When a food product is FORTIFIED with one of the above... it must exist @ >100%


Class II nutrients (>80%):

* vitamins
* minerals
* protein
* total carbohydrate
* dietary fiber
* other carbohydrate
* polyunsaturated
* monounsaturated fat
* potassium

The Third Group (120% or less) nutrients include:

* calories
* sugars
* total fat
* saturated fat
* cholesterol
* sodium

Reasonable excesses of class I and II nutrients above labeled amounts and reasonable deficiencies of the Third Group nutrients are usually considered acceptable by the agency within good manufacturing practices.


So... since the majority of the calories come from items in class ii (and are calculated from them according to the rules I posted earlier), or from the third group, neither of which require 100% or more... (one of which is 80% or more... the other which is less than 120% but doesn't have a floor)... it is just blatantly false to claim the calories will always be higher than on the label.


Something like a protein powder must have 100% of the protein it claims to have. But calories is never in the 100%+ category.

I can read what I cited. A product could contain 140% of the carbs, protein, and unsaturated fat, and it would be in compliance. Hell, it could have 250% of the above, and it would be in compliance.

The sugars and fats can't be more than 120%, but since they're what appeals to a lot of palates, I'd imagine you're not going to see very low amounts compared to what the label says (although technically they could be in compliance at 20% of the stated amount). They're going to want to make those numbers appear as low as possible to appeal to consumers.

Eoghann

This is why we use averages people.

lemurcat12

A product could contain 140% of the carbs, protein, and unsaturated fat, and it would be in compliance. Hell, it could have 250% of the above, and it would be in compliance.

The sugars and fats can't be more than 120%, but since they're what appeals to a lot of palates, I'd imagine you're not going to see very low amounts compared to what the label says (although technically they could be in compliance at 20% of the stated amount). They're going to want to make those numbers appear as low as possible to appeal to consumers.

But obviously, carbs, proteins, and unsat fat have calories (and there are requirements about how to come up with the counts in addition to the percentage rules), and, as cited above:

5) A food with a label declaration of calories, sugars, total fat, saturated fat, trans fat, cholesterol, or sodium shall be deemed to be misbranded under section 403(a) of the act if the nutrient content of the composite is greater than 20 percent in excess of the value for that nutrient declared on the label. Provided, That no regulatory action will be based on a determination of a nutrient value that falls above this level by a factor less than the variability generally recognized for the analytical method used in that food at the level involved.

WalkingAlong

Ah, okay. Thanks. But in the end, then, the best we can do is weigh everything and just deal with the rest. How irritating!

Yeah, it is especially irritating when you're trying to get a best estimate for your TDEE based on calories in (which are full of error) and change in weight (tons of error in weight measurements). But, that's all we have to work with (unless you have access to really high tech labs that will analyze everything for you).

All that said, the long term averages (average daily intake for week+ lengths of time & average daily weight for week+ lengths of time) tend to be reasonably good approximations of the actual values. If anything, it helps one learn to relax about daily ups and downs on the scale and minor (hopefully rare) swings above your calorie goals. In the big picture, both of those are easily dwarfed by the errors we can't control. As long as the long term numbers are going in the right direction, keep doing what you're doing.

I agree with this overall. I think MFP people get too much faith in the numbers and it trips them up because they think that if they weigh foods their estimate is correct. So if they estimate their intake at 1200/day and are not losing weight, they think it's impossible so they're either broken or not eating enough. They might be weighing out 1200/day that is actually 1400 and forgetting to log another 200 so really eating 1600. For some of us, 1600 might mean losing a pound a month. And when you add in 'netting' and errors in estimating exercise calories, it's compounded.

So you get threads on "1200 and not losing!" And the response is "Eat more!" "You have to fuel your workouts!" Etc. So the poor person does and gains and decides it's just too hard and quits, probably thinking they messed up their metabolism from undereating at 1200 (which was actually 1600 and working fine but slowly).