I was going to respond with something like, "I really don't think FDA is 
that silly" but then I found this FAQ posting on FDA.gov under "Industry 
Resources on the Changes to the Nutrition Facts Label":


      Added Sugars

*16. Are the sugars in a jar of honey or a bag of sugar added sugars? If 
so, what should the total and added sugars declaration look like?*

Yes, the sugar in a jar of honey and the sugar in a bag of sugar are 
added sugars. The definition of added sugars includes sugars that are 
either added during the processing of foods, or are packaged as such, 
and include sugars (free, mono- and disaccharides), sugars from syrups 
and honey, and sugars from concentrated fruit or vegetable juices that 
are in excess of what would be expected from the same volume of 100 
percent fruit or vegetable juice of the same type. The definition 
excludes fruit or vegetable juice concentrated from 100 percent fruit 
juice that is sold to consumers (e.g. frozen 100 percent fruit juice 
concentrate) as well as some sugars found in fruit and vegetable juices, 
jellies, jams, preserves, and fruit spreads. Please see 21 CFR 
101.9(c)(6)(iii) on page 33980 of the Nutrition Facts Label Final Rule 
for the definition of “Added Sugars.” For example the total sugars for a 
serving of honey would be 17 grams (g) and the added sugars declaration 
would also be 17g.

FDA defined sugars from honey as added sugars in the final rule. The 
agency has heard concerns from the honey industry about declaring the 
sugars in a jar of honey as added sugars, including that the sugar in 
honey is not added to the product. FDA plans to invite further comment 
in the near future.


Randall Austin
Puzzled in North Carolina

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