No Added Sugar vs Sugar Free NZ: Check Claim Evidence

A food business may remove table sugar from a recipe and assume that “no added sugar”, “sugar free” and “unsweetened” are interchangeable. They are not. New Zealand food labels and advertisements need a claim-specific review of the ingredients, process, nutrient information and overall message. This guide focuses on ordinary retail foods, not a complete assessment of special-purpose products or alcoholic drinks.

Separate no added sugar, sugar free and other claims

Under Standard 1.2.7 on nutrition content claims, claims include express and implied representations. The Code also applies to relevant food advertising. A phrase on a social-media tile therefore needs the same evidence discipline as the front of a package. Changing the wording slightly does not necessarily change what consumers understand.

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The sugar entry in Schedule 4’s nutrition claim conditions lists “% Free”; it does not supply a general 0.5 g/100 g rule for an absolute “sugar free” statement. Do not copy a United States or European threshold into a New Zealand claim file. Nor does the absence of a dedicated absolute-free threshold remove the need for accurate, substantiated wording.

The Commerce Commission’s guidance on accurate health and nutritional claims explains that claims must not mislead and businesses should be able to prove them. Read the full pack and advertisement together. A qualifying sentence elsewhere does not automatically correct a prominent statement that gives the wrong impression.

What the amended no-added-sugar conditions check

The following explains the amended Schedule 4 route. Transitional arrangements still matter in October 2026, so do not use this section alone to conclude that every product following an earlier permitted route is unlawful. For a new formulation or artwork project, record the route you are applying and check its complete conditions.

1. The food itself and its added ingredients: the food must not itself be an added sugar and must not contain an added sugar as an added ingredient. This includes ingredients within compound ingredients, not just ingredients added directly by the final manufacturer.
2. The definition of added sugar: review the actual list in Schedule 4. It extends beyond white sugar to materials such as honey, glucose syrup, malt, malt extracts and maltodextrin. Concentrated or deionised fruit and vegetable juices are addressed, with a specified beverage exception. “Natural” is not an exemption from this review.
3. Total sugars: under the amended route, the food must not exceed 10 g/100 g for solid food or 7.5 g/100 mL for liquid food. These are no-added-sugar conditions, not the lower limits for a low-sugar claim.
4. Processing: check whether carbohydrate hydrolysis increases the concentration of hexose monosaccharides and disaccharides. The amended condition contains an exception when their concentration is not more than 1.5%. This requires a product-specific process assessment, not an assumption from the ingredient list.

Apply the relevant form-of-food rules in Standard 1.2.7—7. Depending on how the food is intended to be consumed, the assessment may concern the food as sold, prepared, reconstituted or drained. Save that decision with the calculations. Comparing a concentrate’s result with a ready-to-drink limit without resolving the applicable form can give the wrong answer.

“Unsweetened” has additional conditions. Under the amended Schedule 4 route it must meet the no-added-sugar conditions and excludes specified intense sweeteners, polyols and other listed substances. Do not automatically add an unsweetened claim simply because a no-added-sugar review has passed.

Keep the applicable transition route in the file

The P1062 variation and P1063 variation contain specific arrangements allowing compliance with the relevant earlier or amended Code during transition, followed by conditions for qualifying stock packaged and labelled before transition ends. A permission to sell qualifying older stock is not an unrestricted permission to print older artwork indefinitely.

For each product, retain the exact provision relied on, the full claim conditions applied, artwork approval date, packaging and labelling dates, and any stock-in-trade decision. Check the operative variation text before setting a deadline. This article does not prescribe a last production or sale date: those dates and the applicable combined amendments need to be confirmed for the product’s chosen route.

Build a claim-specific evidence file

A finished-product sugars result cannot show whether an added ingredient was used or whether a process changed the sugar profile. Conversely, an ingredient list alone does not establish the finished product’s nutrient amount. Bring both sources together and identify where technical review or appropriate analysis is needed.

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Check Standard 1.2.8’s nutrition information requirements as well as the claim threshold. For claims requiring nutrition information about sugars or carbohydrate, a nutrition information panel must include the presence or absence of dietary fibre as specified; absence is shown as 0. Do not add a headline sugar claim and leave the supporting nutrition information unchanged without review.

Use the unrounded evidence appropriate to the assessment, rather than treating a displayed rounded figure as proof of absence. Discuss the analytical method, reporting limit and relevance of the sample with a competent provider when analysis is used. A result describing one sample does not by itself establish every future batch or the exact impression of a proposed claim.

Worked example: no added sugar does not mean no sugars

Hypothetical example: a business is reviewing a plain yoghurt containing milk and cultures. Its supported total-sugars value is 5.2 g/100 g. A recipe and process review is still needed, but this value is below the amended 10 g/100 g no-added-sugar ceiling for solid food. It is above the 5 g/100 g low-sugar limit. The business cannot turn that numerical check into a “sugar free” conclusion: sugars remain present.

If the same business adds a fruit preparation, it must review the preparation’s complete formulation, not only its product name. A compound ingredient may contain a material relevant to the added-sugar definition. Any revised recipe also needs its own nutrient basis and claim decision. The example is not an approval of a particular yoghurt label.

Before approving a claim for print or online use, confirm:

• The exact claim and consumer impression are identified; no-added-sugar, sugar-free, low and reduced claims are assessed separately.
• The complete recipe, compound ingredients and applicable process conditions have been checked.
• Units, food form, nutrient basis and relevant variability are appropriate.
• The selected Code and transitional route are recorded with the full conditions, rather than isolated favourable extracts.
• Required nutrition information, including any claim-triggered declarations, agrees with the artwork.
• Website and promotional statements use the approved wording, with a named change-review owner.

Frequently asked questions

Arrange a review before committing to artwork

AFVA’s food labelling review service can identify possible label and claim-evidence gaps. Provide the full recipe, compound-ingredient specifications, process information, nutrient evidence and proposed wording. Our guide to protein claims on New Zealand food labels explains another claim-specific example. Contact AFVA to scope a sugar-claim label review before printing or changing the product listing. The review is not regulatory approval; final responsibility stays with the food business.

General information checked on 31 October 2026. The amended-route explanation is not a substitute for confirming the applicable complete Code and transitional provisions for a particular product. Suggested records and the worked example are practical guidance.