FDA rounding rules for nutrition labels
Rounding is where a correct calculation turns into an incorrect label. These are the rules from 21 CFR 101.9(c), in one table, with the two places people get them wrong: the %DV bands and the sub-threshold zeros.
1. The rounding table
Every mandatory nutrient, in the order it appears on the panel. The citation column is the paragraph of 21 CFR 101.9 that sets the rule.
| Nutrient | Rounding rule | Citation |
|---|---|---|
| Calories | Nearest 5-calorie increment up to and including 50 calories; nearest 10-calorie increment above 50. Less than 5 calories may be expressed as zero. | (c)(1) |
| Calories from saturated fat (voluntary) | Same increments as calories. | (c)(1)(ii) |
| Total fat | Nearest 0.5 g below 5 g; nearest 1 g at 5 g and above. Less than 0.5 g is expressed as zero. | (c)(2) |
| Saturated fat | Same as total fat. If the food has less than 0.5 g total fat and no fat claims are made, the row is not required. | (c)(2)(i) |
| Trans fat | Same as total fat. | (c)(2)(ii) |
| Poly- and monounsaturated fat (voluntary) | Same as total fat. | (c)(2)(iii)–(iv) |
| Cholesterol | Nearest 5 mg. Not required if under 2 mg. If the food contains 2–5 mg you may state "less than 5 milligrams". | (c)(3) |
| Sodium | Expressed as zero below 5 mg; nearest 5 mg from 5 to 140 mg; nearest 10 mg above 140 mg. | (c)(4) |
| Total carbohydrate | Nearest 1 g. Below 1 g, "Contains less than 1 gram" or "less than 1 gram" may be used. Below 0.5 g, may be expressed as zero. | (c)(6) |
| Dietary fiber | Nearest 1 g, with the same "less than 1 gram" and zero carve-outs. Under 1 g, declaration is optional. | (c)(6)(i) |
| Soluble and insoluble fiber (voluntary) | Same as dietary fiber. | (c)(6)(i)(A)–(B) |
| Total Sugars | Nearest 1 g. Below 1 g, "Contains less than 1 gram" or "less than 1 gram". Below 0.5 g, may be zero. Not required at all below 1 g if no sweetener or sugar claim is made. | (c)(6)(ii) |
| Added Sugars | Same as Total Sugars — nearest 1 g, with the "less than 1 gram" and zero carve-outs. | (c)(6)(iii) |
| Sugar alcohol (voluntary) | Same as Total Sugars. | (c)(6)(iv) |
| Protein | Nearest 1 g. Below 1 g, "Contains less than 1 gram" or "less than 1 gram". Below 0.5 g, may be zero. | (c)(7) |
| Fluoride (voluntary) | Zero below 0.1 mg; nearest 0.1 mg up to 0.8 mg; nearest 0.2 mg above 0.8 mg. | (c)(5) |
2. The two %DV rules — and this is the part people get wrong
The percent Daily Value column does not use the rounding rules above. It has two of its own, and they are very different.
| Applies to | Rule | Citation |
|---|---|---|
| Everything except vitamins and minerals | Nearest whole percent. This includes sodium, even though sodium is a mineral — it is not in the vitamin-and-mineral group for this purpose. | (d)(7)(ii) |
| Vitamins and minerals (vitamin D, calcium, iron, potassium, and any voluntarily declared vitamin or mineral) |
Below 1% → not declared 1% up to 2% → 2% Up to 10% → nearest 2% Above 10% to 50% → nearest 5% Above 50% → nearest 10% |
(c)(8)(iii) |
The wide bands for vitamins and minerals are not a cosmetic choice. Worked through, they are what makes an iron figure of 8 mg print as 45% rather than 44%: 8 mg is 44.4% of the 18 mg Daily Value, and applied to that number the "nearest 5%" rule gives 45%. Applying the nearest-whole-percent rule instead gives 44% — a value the FDA's own published sample panel does not contain.
Quantities of vitamins and minerals present at less than 2 percent of the Daily Value need not be declared at all, though you may declare them as zero or flag them with an asterisk and a "contains less than 2 percent of the Daily Value" note.
You may compute the %DV before rounding
21 CFR 101.9(d)(7)(ii) allows the percent to be calculated by dividing either the amount declared on the label, or the actual amount before rounding, by the Daily Value. Both are permitted. What matters is that you apply the same choice consistently across the panel — a label where some rows are computed before rounding and others after is hard to defend.
3. The zeros are not errors
A label littered with zeros looks suspicious to a first-time producer, so it is worth being concrete. Each of these declarations is required by the rules above and is correct:
| You calculated | You must print | Because |
|---|---|---|
| 4.4 mg sodium | 0 mg | Below 5 mg → expressed as zero |
| 0.17 g trans fat | 0 g | Below 0.5 g → expressed as zero |
| 0.03 g added sugars | 0 g | Below 0.5 g → expressed as zero |
| 0.6 g added sugars | "less than 1 gram" | Below 1 g → alternative permitted (and the row may be omitted entirely if no sugar claim is made) |
| 0.8% iron | 0% | Vitamins and minerals are not declared below their 2% threshold |
Rounding down to zero is not a loophole and rounding up is not required. The declared value still has to be the value your recipe produces — see the tolerance below.
4. How far off is allowed to be "off"
The compliance standard is not exact equality, and it does not run symmetrically. From 21 CFR 101.9(g):
- Nutrients you want less of — calories, total sugars, added sugars (when the only source of sugars is added sugars), total fat, saturated fat, trans fat, cholesterol, sodium — the label is misbranded if the actual nutrient content exceeds the declared value by more than 20 percent. Under-declaring is the risk.
- Nutrients you want more of — added vitamins and minerals, protein, total carbohydrate, dietary fiber, poly- and monounsaturated fat — the composite must be at least 80 percent of the declared value for naturally occurring (Class II) nutrients, and at least equal to the declared value for added (Class I) nutrients.
A 20 percent allowance is not a license to declare a flattering number. The declared figure must be the one your recipe and your records produce; the tolerance exists to absorb lab variability and natural variation between batches, not to absorb optimism.
5. Where the numbers come from matters more than the rounding
Every rule on this page is deterministic. If two people round the same per-serving figure, they get the same label. The divergence between two labels almost always sits one level up: in the per-serving figure itself. The usual culprits are volume-versus-weight conversions, cooking losses, and counting servings after the product has lost water rather than before.
We walk through the arithmetic and the error sources in how to calculate nutrition facts from a recipe, and the sugar-specific rules are in how to calculate added sugars.
These rules are implemented, not approximated
Enter your ingredients and the panel is built with the rounding in 21 CFR 101.9 — including the separate vitamin and mineral %DV bands. Our output is checked line by line against the FDA's own sample panel.
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