by Thom King – Founder, Chief Innovation Officer, Food Scientist, Icon Foods
Let’s face it, labeling sweeteners and fibers can feel like navigating a regulatory minefield. To help cut through the noise, I’ve pulled together practical guidance on how these ingredients are commonly declared in line with FDA 21 CFR requirements. This covers ingredient statements, dietary fiber labeling, inclusion criteria, and nutrient content claims like “sugar-free” or “reduced sugar.”
Quick disclaimer: This is general guidance only. It’s not legal advice, always run final labeling decisions by your regulatory team before going to market.
Sweetener Labeling Guidelines
Erythritol
✅Acceptable:
- “Erythritol” (most common)
- “Sugar alcohol (erythritol)” (sometimes used when grouping with sorbitol, maltitol, etc.)
🚫 Not acceptable:
- “Natural sugar” or “fruit sugar alcohol” (misleading under FDA definitions)
Notes:
- Must be listed under Total Carbohydrate with a subline: “Sugar Alcohol ___ g.”
- If used in trace amounts strictly for flavor, it may sometimes fall under natural flavors.
Stevia
✅ Acceptable:
- “Stevia leaf extract”
- “Steviol glycosides”
- “Rebaudioside A/M/D/etc.”
- “Stevia extract (Rebaudioside A)”
🚫 Not acceptable:
- “Stevia” alone → too vague; may imply crude leaf.
- “All-natural sugar” → misleading; not a sugar.
Notes:
- Doesn’t contribute to nutrition panels; appears only in the ingredient statement.
- If used strictly for flavor, can sometimes be declared as natural flavor.
Allulose
✅ Acceptable:
- “Allulose”
- “D-allulose”
- “D-psicose”
Notes:
- Recognized as a rare sugar.
- Excluded from Total Sugars and Added Sugars, but still required in the ingredient statement.
- Must be included in calorie count (0.4 kcal/g).
Monk Fruit
✅ Acceptable:
- “Monk fruit juice concentrate”
- “Monk fruit extract”
- “Siraitia grosvenorii (Luo Han Guo) fruit extract/juice concentrate”
Xylitol
✅ Acceptable:
- “Xylitol” (preferred)
- “Sugar alcohol” (if grouped with other polyols)
- “Sweetener (xylitol)”
Notes:
- Must be listed under “Sugar Alcohol.”
- Include laxative warning if serving exceeds 20g.
Other Icon-Specific Sweetener Notes
RM95D: May be declared as “Stevia extract (Rebaudioside M/D blend).” Depending on application, it can also fall under natural flavors and sweetness modulators (see below).
Icon Foods Product Labeling Notes Icon Foods Product Labeling Notes
| Brand Name | Ingredients | Labeling Notes |
| ErySweet | Erythritol | Count as sugar alcohol; disclose grams when making “sugar-free” claims. |
| ErySweet+ | Erythritol, Stevia | Declare individually. Meets “reduced sugar” if <25% sugar reduction. |
| IconiSweet | Erythritol, Allulose, Stevia, Monk Fruit | Declare individually. |
| IconiSweet Gold | Erythritol, Allulose, Monk Fruit | Declare individually; substantiate “brown sugar replacement” claims. |
| KetoseSweet | Allulose | Declare individually. |
| KetoseSweet + Monk Fruit | Allulose, Monk Fruit | Declare individually; monk fruit GRAS per supplier levels. |
| KetoseSweet + Stevia | Allulose, Stevia | Declare individually. |
| KetoseSweet+ | Allulose, Stevia, Monk Fruit | Declare individually. Suitable for “No Sugar Added” if CFR 101.60(c) criteria met. |
| LoSweet | Erythritol, Monk Fruit | Declare individually. |
| MonkSweet+ | Monk Fruit, Stevia, Erythritol | Declare individually; substantiate “1:1 sugar replacement.” |
| MonkSweet V25 / V40 / V50 | Monk Fruit Extract (25–50% Mogroside V) | Label as “Monk Fruit Extract.” Mogroside % not required on label; keep in specs. |
| MonkSweet LS / LS4 | Monk Fruit Stevia Extract | Label as “Monk Fruit and Stevia Extract.” Positioning as sweetener and masking agent. |
| SteviaSweet RM95 / RA75+ / RD95 / SG95e | Stevia Extracts (various Reb isomers) | Reb isomers not required, but recommended for transparency. |
| RM95D | Stevia Extract Blend | Can be labeled as stevia extract or, in some uses, as natural flavor / sweetness modulator. |
| XeroSweet | Xylitol | Must include laxative warning if >20g per serving. |
| XeroSweet+ | Xylitol, Stevia | Declare individually. |
Fiber Labeling Notes
| Brand Name | Ingredients | Notes |
| PreBiotica (Inulin / AG / JA / P95) | Chicory Root, Agave, Jerusalem Artichoke Inulin, Oligofructose | Declare by source (e.g., “Chicory Root Fiber”). Must meet FDA dietary fiber definition. |
| FibRefine P90 / L90 / Organic | Soluble Tapioca Fiber | Label as “Soluble Tapioca Fiber.” Supplier must substantiate fiber inclusion. |
| FibRefine HG | Hydrolyzed Guar Fiber | Label as “Partially Hydrolyzed Guar Gum” or “Guar Fiber” per CFR. Stable in beverages. |
| FibRefine 3.0 | Soluble Tapioca Fiber (improved stability) | Declare as “Soluble Tapioca Fiber.” Enhanced thermal/pH tolerance. |
| Organic FibRefine 3.5 | Organic Soluble Tapioca Fiber | Declare as “Organic Soluble Tapioca Fiber.” Supplier documentation required for dietary fiber claims. |
| FibRefine 4.0 | Soluble Tapioca Fiber (next-gen) | Label as “Soluble Tapioca Fiber.” Designed for lower viscosity + better clarity. |
| PolIdex5™ Polydextrose | Polydextrose | Label as “Polydextrose.” Counts toward dietary fiber. |
Natural Flavors & Sweetness Modulators
- ThauSweet DRM / VRM → Declare thaumatin as natural flavor (FEMA GRAS #3732). Sweeteners in the blend (erythritol, monk fruit, stevia, fiber) must still be declared individually.
- RM95D → Dual-purpose. Can be labeled as stevia extract (sweetener) or natural flavor (modulator), depending on use level and function.
Bottom line: Labeling isn’t just compliance, it’s credibility. Use clear, compliant declarations, and you’ll keep your brand out of trouble while building trust with consumers.
Since 1999, Icon Foods has been your reliable supply-chain partner for sweeteners, fibers, sweetening systems, inclusions, and sweetness modulators.
Reach out to your Icon Foods representative for a food and beverage formulating toolkit with samples, documentation, and formulation guidance.
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