Manufacturers have two options in declaring the amount of added sugars in a baked food when sugar is added for fermentation during the leavening process, according to a Food and Drug Administration draft guidance issued Jan. 4.

The mandated labeling of added sugars on the Nutrition Facts Panel was part of an F.D.A. final rule issued last May and scheduled to begin going into effect in July 2018.

In the fermentation process, yeast consumes some of the sugar in the baked food, decreasing the amount of added sugars. Manufacturers may declare the amount of added sugars found in a product either before fermentation or after fermentation.

When declaring the amount of added sugars after the fermentation process, manufacturers must make and keep records of all relevant scientific data and information that demonstrates the amount of added sugars after fermentation. A narrative also should explain why the data and information are sufficient to demonstrate the amount of added sugars.

Manufacturers also may declare the amount of added sugars prior to non-enzymatic browning and/or fermentation. The F.D.A. acknowledged in this instance the amount of added sugars declared conceivably could exceed the amount of total sugars determined through chemical analysis.

“In such a case, you should declare the same amount for added sugars as the amount of total sugars obtained through analytical testing for a serving of the food,” the F.D.A. said in the draft guidance, which may be found here.

The listing of mono- and disaccharides as either “total sugars” or “added sugars” would be determined by the type of hydrolysis. Sugars produced through incidental hydrolysis would be listed in a “total sugars” declaration, not as “added sugars.” If a manufacturer purposely employs a hydrolysis step to increase the sugar content of a food, the sugar generated through the hydrolysis step would be listed as “added sugars.”

The F.D.A. published its final rule, “Food Labeling: Revision of the Nutrition and Supplements Facts Labels” in the May 27, 2016, issue of the Federal Register. Manufacturers with $10 million or more in annual food sales must be in compliance with the new labeling rules by July 26, 2018. Manufacturers with less than $10 million in annual sales have until July 26, 2019.

The final rule changes “sugars” to “total sugars” in the Nutrition Facts Panel and requires the amount of “added sugars” to be indented and appear below “total sugars.” The final rule defines added sugars as sugars that either are 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% fruit or vegetable juice of the same type.

The F.D.A. now is accepting public comments on the draft guidance for 60 days following its publication in the Jan. 5 issue of the Federal Register found here. Electronic comments may be sent to Written comments may be sent to the Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. All comments should be identified with the docket number Docket No. FDA-2016-D-4414.