Nutrient Content Claims on Amazon Food Listings: What 21 CFR 101.13 Allows

Nutrient content claims look like the safest copy on a food listing. Nobody is promising to cure anything. "Low carb," "high energy," "packed with antioxidants" and "superfood" read like ordinary marketing, and that is exactly why they get past internal review and onto Amazon, where they turn into findings.

The reason is that a nutrient content claim is not free text. It is a defined term. FDA decides which terms exist, what each one means, and what number on the Nutrition Facts panel a food has to hit to use it. A term FDA has not defined is not a claim you get to make, no matter how true it feels. This guide covers the undefined terms that cause the most trouble, the thresholds behind the terms that are defined, and how to rewrite copy so it says what the panel supports.

A nutrient content claim is a defined term

Under 21 CFR 101.13(b), a food label may make a claim about the level of a nutrient only if that claim is defined by regulation in 21 CFR 101 subpart D, or has been authorised under 21 CFR 101.69, FDA's petition process for new claims. The defined claims are the familiar ones: low fat, fat free, sugar free, low sodium, good source of fiber, high in calcium. Each comes with a threshold measured per reference amount customarily consumed (RACC), which is the serving basis the regulation uses.

Amazon's misleading and prohibited claims policy is the channel-side counterpart. A nutrient claim the panel cannot support, or a term that has no definition at all, is a claim about the product that cannot be substantiated, and Amazon can suppress a listing that carries one. This is one of the reasons the Nutrition Facts panel image is a listing requirement: without it, no one can tell whether "good source of protein" is true. Our guide to Amazon's Nutrition Facts and ingredient image requirements covers that side.

Terms with no FDA definition

These are the phrases that fail before any threshold is checked, because the regulation does not contain them.

• "Low carb" and "low-carb." FDA has never defined a low-carbohydrate claim. The fact that the product has 4 g of carbohydrate per serving does not rescue the phrase, because there is no number the phrase corresponds to.
• "High energy." Energy is not a nutrient with a defined claim. Calories are declared, but "high energy" is not a calorie claim FDA recognises, and as marketing it drifts toward an implied performance claim.
• "High in antioxidants" and "rich in antioxidants." 21 CFR 101.54(g) allows an antioxidant claim only when it names the nutrients that have recognised antioxidant activity, each named nutrient has an established RDI, and the food meets the high or good source threshold for each one. An unnamed, unmeasured "antioxidants" claim meets none of those conditions.
• "Low glycemic" and "low GI." Not a defined nutrient content claim.
• "Superfood." An implied nutrient claim with no definition. It says the food is nutritionally exceptional without saying which nutrient or by how much.

The fix for every one of these is the same. Either replace the term with a defined claim the panel supports, or describe the nutrient value factually. "5 g net carbs per serving" is a statement of fact that the panel can back up. "Low carb" is a claim with no legal meaning.

The thresholds behind defined claims

When a claim is defined, the question becomes whether the Nutrition Facts panel supports it. The thresholds that come up most on grocery listings, all per RACC:

Claim	Threshold
"High in," "rich in," "excellent source of" a nutrient	20% or more of the Daily Value
"Good source of" a nutrient	10% to 19% of the Daily Value
"Low sodium"	140 mg or less
"Very low sodium"	35 mg or less
"Sodium free"	Under 5 mg
"Sugar free"	Under 0.5 g sugars
"Low fat"	3 g or less
"Fat free"	Under 0.5 g
"Low calorie"	40 kcal or less

These definitions live in 21 CFR 101.54 through 101.69, and FDA's overview of label claims for conventional foods is the readable entry point. The practical test is mechanical: find the claim in the copy, find the matching line on the panel, compare. A granola that says "excellent source of fiber" while its panel shows fiber at 11% of the Daily Value is making a "good source" claim with "excellent source" words, and that mismatch is a finding.

The mismatch usually is not dishonesty. A recipe changed, a serving size changed on the panel, or the copy was cloned from a sister product with a different formula. The panel moved and the bullets did not follow.

Two claims with extra conditions

Two defined claims deserve their own paragraph because they fail for reasons other than a simple number.

"High protein." Protein claims cannot be checked from grams alone. Under 21 CFR 101.9(c)(7), a protein claim requires the panel to show a percent Daily Value for protein, and that percentage has to be corrected for protein quality using the PDCAAS method. A panel that lists "10 g protein" with no %DV does not support "high protein," even though 10 g sounds like a lot. If you want to make the claim, the panel has to carry the adjusted %DV, and it has to meet the 20% threshold.

"Healthy." FDA finalised an updated definition of "healthy" in 2024 with food-group and nutrient-limit criteria, and a compliance date of 2028-02-25. FDA's page on the term healthy explains the criteria. Until the new criteria are met, "healthy" is a defined claim your product either qualifies for or does not, and the word is not a casual adjective on a food label the way it is in a blog post.

Where Amazon finds these claims

Sellers often clean the bullets and leave the same phrases elsewhere. A scan of a food listing reads nutrient claims in:

• Title, bullets and description. The obvious surfaces.
• A+ content. Both the text modules and text rendered inside A+ images.
• Backend search terms. Invisible to shoppers, but part of the listing content. "Low carb snack" and "superfood" in the search terms field are the same claims as in a bullet.
• Images. Infographics and badges that say "HIGH PROTEIN" or "Antioxidant Rich" are read as text.

If the panel image is in the gallery, every one of those claims is checkable against it, and the ones that fail stand out.

Writing the factual alternative

The move that fixes most findings is to replace the adjective with the number and let the panel do the talking.

Risky copy	Why it fails	Factual alternative
"Low carb granola"	No FDA definition	"9 g carbohydrate per 40 g serving"
"High energy bar"	Energy is not a defined claim	"200 calories per bar"
"Rich in antioxidants"	Unnamed nutrients, no RDI	"Excellent source of vitamin C" if the panel shows 20%+ DV
"Superfood blend"	Implied, undefined	Name the ingredients and any defined claim they support
"High protein" with 10 g and no %DV	Needs PDCAAS-adjusted %DV at 20%+	"10 g protein per serving," or add the %DV to the panel first
"Excellent source of fiber" at 11% DV	Wrong tier	"Good source of fiber"

Notice that the alternatives are not weaker. "9 g carbohydrate per serving" tells a low-carb shopper exactly what they want to know, without claiming a definition that does not exist. A shopper scanning for protein sees "10 g protein" and makes their own judgement.

A quick checklist per ASIN

With the current panel open beside the listing:

1. List every nutrient word in the title, bullets, description, A+ and search terms: low, high, rich, excellent, good source, free, superfood, antioxidant, energy, glycemic, healthy.
2. Strike any term not in 21 CFR 101 subpart D. Replace with a number or a defined claim.
3. For each defined claim, find the panel line and confirm the tier. Downgrade "excellent" to "good" or remove it if the number does not reach it.
4. For "high protein," confirm the panel shows a PDCAAS-adjusted %DV at 20% or more.
5. Check infographics and badges for the same words.
6. Confirm the panel image in the gallery is the current formula, so the comparison you just did is the one Amazon will do.

Doing this for one product takes a few minutes. Doing it for a catalogue, including every variation child and every A+ module, is where it stops getting done. Verid8 runs the comparison for you: it reads the Nutrition Facts panel in your gallery, finds every nutrient content claim across text and images, flags undefined terms and tier mismatches with the regulation that applies, and suggests a factual rewrite for each. The Grocery and Gourmet Food page lists the other food rules it checks alongside this one.

Nutrient content claims are the one area of food marketing where the rulebook is a lookup table. Use the words FDA defined, hit the numbers the panel shows, and say the rest in grams.