Zero Sugar vs. Sugar Free vs. No Added Sugar

"Zero Sugar," "Sugar Free" and "No Added Sugar" can sound similar to shoppers.

Under federal food-labeling rules, they are not the same claim.

That distinction is now visible across dozens of allulose lawsuits.

The most important appellate ruling, Franco v. Chobani, involved a sugar-free theory. Many newer cases challenge added-sugar wording instead.

Quick comparison

The exact package wording and context control the analysis.

Sugar Free and Zero Sugar

Section 101.60(c)(1) addresses terms including:

• Sugar Free;
• Free of Sugar;
• No Sugar;
• Zero Sugar;
• Without Sugar;
• Sugarless;
• similar claims.

The regulation ties those claims to a threshold of less than 0.5 grams of sugars under the applicable serving framework and cross-references the sugar definition in § 101.9.

That cross-reference was central in Franco.

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What Franco established

The Seventh Circuit held that allulose falls within the regulation's definition of sugar because allulose is a monosaccharide and the definition includes all free mono- and disaccharides.

The court also reversed the preemption-based dismissal and held that the plaintiffs had plausibly alleged deception.

That is strong authority for the regulatory definition.

It does not automatically decide every case involving "No Added Sugar."

No Added Sugar and Zero Added Sugar

Section 101.60(c)(2) addresses claims that sugars were not added during processing or packaging.

The provision includes conditions involving:

• sugars added during processing;
• ingredients containing added sugars;
• ingredients that function as substitutes for added sugars;
• processing that increases sugar content.

That analysis is not identical to the less-than-0.5-gram framework associated with sugar-free claims.

How often do the different claims appear in litigation?

Several of these claim types appear repeatedly among the verified cases.

The current verified snapshot includes:

• 27 cases tagged zero_sugar;
• 14 tagged zero_grams_sugar;
• 12 tagged sugar_free;
• 9 tagged no_added_sugar;
• 8 tagged zero_added_sugar;
• 5 tagged no_sugar_added;
• 4 tagged zero_grams_added_sugar;
• 1 tagged zero_grams_total_sugars.

These totals overlap because one case can carry multiple tags.

The data makes clear why the site needs more than one generic "allulose lawsuit" explanation.

Real examples from the cases

Chobani

Reported challenged wording centers on Zero Sugar / sugar-free representations.

Liquid Death

Tracked cases include "0g Sugar" and "Zero Sugar" theories.

KIND

The dataset records reported "ZEROg Added Sugar" wording.

Special K

Cases involve Zero Added Sugar representations.

Magic Spoon

Tracked reported wording includes "0g Total Sugars," "0g Added Sugar" and "No Added Sugar."

Ray's / Ken's Foods

Cases involve "No Sugar Added" theories.

Nutrition Facts is a separate layer

FDA currently allows allulose to be excluded from Total Sugars and Added Sugars declarations on the Nutrition Facts panel under enforcement discretion.

That does not mean every statement elsewhere on the package is governed by the same rule.

A front-label "Zero Sugar" claim and the Total Sugars line inside the Nutrition Facts panel are related but distinct legal questions.

Why "0g Sugar" needs context

A numerical statement can appear:

• on the front of the package;
• in a nutrition callout;
• next to other macro claims;
• inside or near the Nutrition Facts presentation.

Why this distinction matters for searchers

A person searching "allulose zero sugar lawsuit" may assume every case is the same.

It is not.

The exact wording can affect:

• the federal subsection at issue;
• the relevance of Franco;
• preemption arguments;
• state-law theories;
• the evidence needed;
• the appropriate internal links.

That is why claim wording is a first-class dataset field, not decorative copy.

Frequently asked questions

Is Zero Sugar the same as Sugar Free?

They are in the same basic federal claim family under § 101.60(c)(1).

Is Zero Added Sugar the same as Zero Sugar?

No. Added-sugar claims are addressed separately under § 101.60(c)(2).

Does 0g Total Sugars mean the product cannot contain allulose?

No. FDA currently permits allulose to be excluded from Total Sugars under enforcement discretion.

Did Franco decide No Added Sugar cases?

No. It is important authority on allulose as sugar and on the theory before the Seventh Circuit, but added-sugar cases can present different regulatory questions.

Sources cited in this guide (5)

• 21 C.F.R. § 101.60
• 21 C.F.R. § 101.9
• FDA allulose guidance
• Franco v. Chobani, LLC
• The alluloselawsuit.com case tracker, with the sources cited on each case page.