Claims & advertising
"No Added Sugar" vs "Sugar Free" vs "Zero Sugar"
No added sugar concerns how a food is formulated; sugar-free concerns its final sugar concentration. A food can contain naturally present sugars and still need a non-addition assessment, while failing the sugar-free limit. Zero sugar should not be treated as an unrestricted alternative phrase.
By the MyFoodLicense team Sources checked 3 min read
In this guide
Apply separate tests
For sugar-free, the cited Schedule I limit is not more than 0.5 g sugars per 100 g or 100 ml. For no added sugar, examine ingredients and processing against the non-addition conditions. A nutrition report and a recipe review answer different parts of the question. Read sugar and non-addition criteria.
Check indirect sugar sources
The non-addition rules address sugar-containing components and ingredients used as substitutes for added sugars, including relevant fruit concentrates or pastes. Honey, sweetened fillings or similar inputs cannot be ignored merely because no bag of sucrose enters the factory.
Consider naturally present sugar
Where the food contains naturally occurring sugars, the applicable accompanying statement must be reviewed. The total-sugars figure should accurately reflect the final product. Do not imply that natural origin makes those sugars disappear from the nutrition or sugar-free assessment.
Review processing and sweeteners
Assess whether the process increases sugar content through the situations addressed by the regulation. A non-sugar sweetener can create its own permission and declaration questions. Removing added sugar does not automatically establish that every substitute is permitted or that the food is healthier.
Use evidence and wording consistently
Retain ingredient specifications, formula, process details, analytical evidence and the approved message. Check product title, pack, listing and influencer copy. No added sugar on the pack should not become contains no sugar on the website. Build the claim file.
A worked example
Hypothetical example
A fruit bar uses date paste to sweeten the recipe and proposes no added sugar because it contains no refined sucrose. The review examines the paste’s role under the non-addition conditions and the final sugar concentration. Neither proposed sugar claim follows simply from avoiding table sugar.
Your practical checklist
- Separate concentration and non-addition assessments.
- Review all sugar-containing components.
- Identify ingredients used as sugar substitutes.
- Check naturally occurring-sugar wording.
- Assess processing and sweetener permissions.
- Align every channel with approved copy.
Download this preparation checklist
For help applying this review to your business, explore our Nutrition Claim Review service. Bring the documents described above so the consultation can focus on the decisions still unresolved.
Frequently asked questions
Can a no-added-sugar food contain sugar?
Yes. Naturally present sugars can remain, subject to the applicable conditions and accompanying statement.
Does honey avoid the added-sugar assessment?
No. Review the full formula and non-addition conditions.
Is zero sugar a free marketing phrase?
No. Assess its consumer meaning and applicable sugar-claim criteria.
Can a sweetener be used without other checks?
No. Permission and label requirements remain separate.
Can a test alone prove no added sugar?
No. The recipe and processing evidence are also necessary.
Official sources and further reading
Checked on 2 October 2026. Gazette notifications and operative directions prevail over compilations and summaries, including this guide.
- Advertising and Claims Regulations compendium, Version IV, 14 December 2022: Nutrition-claim thresholds and general claim conditions. Protein uses RDA-based alternatives, not a universal percentage-of-energy rule.
- Labelling and Display Regulations compendium, Version VIII, 9 September 2025: Regulation 5: retail declarations, nutrition, dates and allergens. Read alongside later amendments and directions.
This guide is general information, not legal advice; the right route depends on your product and business facts. Examples marked hypothetical are illustrations, not client cases. MyFoodLicense is an independent consultancy and is not affiliated with FSSAI; applications are decided by the competent authority on the official FoSCoS portal.