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Energy - Nutrition Labelling - USA

 Updated 2015-08-15

 U. S. Federal Regulations on nutrition labelling

Nutrition Labeling and Education Act (NLEA) of 1990

Nutrition labelling is regulated in the U.S. through the Public Law 101-535 Nutrition Labeling and Education Act of 1990, and administered by the U.S. Food and Drug Administration, 21 CFR 101.9.

The nutrition labelling rules in U.S. differs from the Codex Alimentarus guidelines and European regulations on several points. The most visible is that the nutrient declarations in the "Nutrition Facts" are listed per "serving" and not as amounts per 100 g. The term serving or serving size "means an amount of food customarily consumed per eating occasion by persons 4 years of age or older which is expressed in a common household measure that is appropriate to the food." This means that the nutrient declarations of different foods may be given on different basis, dependent on the serving size.

In addition to the basis on which the nutrient declarations are given, there are also some important differences in the way the nutrients and energy calculations are defined:

Protein calculated on the basis of the factor of 6.25 times the nitrogen content of the food as determined by the appropriate method of analysis as given in the ‘‘Official Methods of Analysis of the AOAC International’’;
Carbohydrate, total or Carbohydratecalculated by subtraction of the sum of the crude protein, total fat, moisture, and ash from the total weight of the food;
Sugars the sum of all free mono- and disaccharides (such as glucose, fructose, lactose, and sucrose);
Sugar alcohols the sum of saccharide derivatives in which a hydroxyl group replaces a ketone or aldehyde group and whose use in the
food is listed by FDA (e.g., mannitol or xylitol) or is generally recognized as safe (e.g., sorbitol);
Other carbohydrate the difference between total carbohydrate and the sum of dietary fiber, sugars, and sugar alcohol, except that if sugar alcohol is not declared;
Fat, total or Total fat defined as total lipid fatty acids and expressed as triglycerides;
Saturated fat or Saturated the sum of all fatty acids containing no double bonds;
Monounsaturated fat or Monounsaturatedcis-monounsaturated fatty acids;
Polyunsaturated fat or Polyunsaturated cis,cis-methylene-interrupted polyunsaturated fatty acids;
Trans fat or Trans the sum of all unsaturated fatty acids that contain one or more isolated (i.e., nonconjugated) double bonds in a trans configuration;
Monounsaturates cis-monounsaturated fatty acids;
Polyunsaturates cis,cis-methylene-interrupted polyunsaturated fatty acids;
Dietary fiber
Soluble fiber 
Insoluble fiber 


Especially the definitions of Carbohydrate, total, calculated by difference and Fat, total calculated as the sum of triglycerides catch the eye.
Although carbohydrate is often calculated by difference in the rest of the world, it is only the U.S. regulations that clearly state this. The NLEA definition of total fat defined as triacylglycerides (TAG) are in line with the FAO recommendations for expressing the fat content of foods (FAO Food and Nutrition Paper 77).

The NLEA provides several ways of calculating the "Caloric content" (the energy content) in several ways

  • Using specific Atwater factors (i.e., the Atwater method) given in Table 13, ‘‘Energy Value of Foods—Basis and Derivation,’’ by A. L. Merrill and B. K. Watt, United States Department of Agriculture (USDA) Handbook No. 74 (slightly revised, 1973)
  • Using the general factors of 4, 4, and 9 calories per gram for protein, total carbohydrate, and total fat, respectively, as described in USDA Handbook No. 74 (slightly revised 1973) pp. 9–11.
  • Using the general factors of 4, 4, and 9 calories per gram for protein, total carbohydrate less the amount of insoluble dietary fiber, and total fat, respectively, as described in USDA Handbook No. 74 (slightly revised 1973) pp. 9–11.
  • Using data for specific food factors for particular foods or ingredients approved by the Food and Drug Administration (FDA) and provided in parts 172 or 184 of 21 CFR Ch. 1, or by other means, as appropriate.
  • Using bomb calorimetry data subtracting 1.25 calories per gram protein to correct for incomplete digestibility, as described in USDA Handbook No. 74 (slightly revised 1973) p. 10.

Thus, there are several ways for calculating energy in foods, which will give (maybe minor) differences between energy values calculated with the different methods.


  • Public Law 101-535 - Nutrition Labeling and Education Act of 1990.
  • U.S. Code of Federal Regulations, 21 CFR 101.9 Nutrition labelling of foods.
  • U.S. Food and Drug Administration:
    Nutritional Labeling and Education Act (NLEA) Requirements (8/94 - 2/95)
  • U.S. Food and Drug Administration:
    Guide to nutrition labeling and Education Act (NLEA) Requirements - Attachment 6-8
  • U.S. Food and Drug Administration:
    Labeling & Nutrition Guidance Documents & Regulatory Information Guidance for Industry
  • U.S. Food and Drug Administration:
    Food Labeling Guide (revised January 2013)
  • Food energy - methods of analysis and conversion factors.
    Report of a technical workshop, Rome, 3-6 December 2002.
    FAO Food and Nutrition Paper 77
    FAO, Rome, 2003.
  • Merrill, A.L. and Watt, B.K.:
    Energy Value of Foods … basis and derivation.
    Agriculture Handbook No. 74, revised February 1973.
    Human Nutrition Research Branch, Agricultural Research Service, United States Department of Agriculture. 


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