Food
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Company
Nutrition • Labeling • Regulatory
THE DUE DILIGEnCE
CHaLLEnGE
a Guide to accurate
Database nutrition analysis
Karen C. Duester, mS, RD, president
Food Consulting Company
Originally presented to National Restaurant Association
Revised November 2012
NRA_cover_Oct2012-2.indd 1
10/22/12 1:36 PM
DUE DILIGENCE WITH
DATABASE NUTRITION ANALYSIS
Due diligence is a term that describes the process of performing
obligatory nutrition analysis tasks. The performance utilizes deep
knowledge of food composition and professional wisdom that leads to
accurate and fully-compliant nutrition information for packaged foods
and restaurant menu items on a per serving basis. The process enables
food labelers to find or reasonably deduce answers when facts aren’t
readily available.
Nutrition Analysis: 8-Step Process
Step 1: Gather Your Data Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Step 2: Set-up Your Raw Materials Database . . . . . . . . . . . . . . . . . . . . . 3
Step 3: Enter the Recipe Ingredients and Amounts . . . . . . . . . . . . . . . . . 4
Step 4: Make Adjustments for Processing . . . . . . . . . . . . . . . . . . . . . . . . 5
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Step 5: Set the Serving Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Step 6: Perform the Due Diligence Checks . . . . . . . . . . . . . . . . . . . . . . . 7
Step 7: Apply the Rounding Rules . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Step 8: Triple-check Your Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Nutrient Content Claims . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10-11
Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
About Food Consulting Company . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
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1
Nutrition Analysis
Step 1:
Gather Your Data Sources
Establish the list of ingredients used in the recipes you will be analyzing.
Determine the nutrients you will be tracking.
Have at hand a research-quality database. Food Consulting Company
uses Genesis R&D from ESHA Research.
Evaluate all supplier specification sheets for usability or need for further
information. Ideally, you want information that includes:
• Unrounded nutrient data
• Complete data for all nutrients you are tracking
• Data for moisture and ash
• Proximates (protein, carbohydrate, fat, moisture, ash) that add up to
100% of the reported weight (typically 100 grams)
• Calories that make sense in the context of 4-4-9 formula, Atwater
factors, or another FDA-allowed method for calorie calculation
• Fat components (saturated, monounsaturated, polyunsaturated, trans)
that make sense in the context of total fat
• Carbohydrate components (dietary fiber, sugars, sugar alcohol, other
carbohydrates) that make sense in the context of total carbohydrate
• The source of the data
• Data that passes your own “common sense” test for the item being
described
2
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Nutrition Analysis
Step 2:
Set-up Your Raw Materials Database
Refer to the list of ingredients in your recipe. Determine which
ingredients will need to be entered into the database as new food items
and which ingredients will be matched with existing food items in the
database. For example, a proprietary sauce manufactured for you will be
a new food item, while a tomato slice will be matched with existing USDA
data which is already in the database.
You may need to interpolate to account for missing values in some
instances. Keep in mind:
• You cannot derive a total trans fat value if you don’t have trans fat
values for all ingredients.
• You cannot correctly account for moisture adjustment when you don’t
have moisture data for all ingredients in your recipe.
• Proximates will not total 100% when you don’t have complete data for
moisture and ash.
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If a value is not reported on a supplier specification sheet, there are
several ways to determine the value. Sometimes values can be deduced
mathematically from trustworthy sources. In other cases, it may be
necessary to go back to the supplier to get the information. Or it may be
necessary to supplement supplier data with laboratory analysis.
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3
Nutrition Analysis
Step 3:
Enter the Recipe Ingredients and Amounts
If your data sources are accurate and complete, you will be able to derive
accurate nutrient values for your recipe (before processing) by entering
the ingredients and amounts into your nutrition analysis software. If you
have sub-recipes or pre-prepped ingredients, consider the following:
• Each sub-recipe needs to be entered individually before you can enter
it into the recipe you are analyzing. For example, if you make your own
pizza sauce and crust, the sub-recipes for each need to be entered to
produce the data for pizza.
• For items that are marinated, dipped, battered or breaded, the parts
left behind in the bowls should not be included in the final calculated
nutrition data.
4
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Nutrition Analysis
Step 4:
Make Adjustments for Processing
Until this step you have accounted for the nutrient values prior to
processing. Processing can affect the nutrient content in important ways.
For example:
• If you are simmering a sauce, soup or other item, you will need to
enter a moisture adjustment to account for the water evaporation.
• If you are baking an item such as a cake, cookies or muffins, you
will need to enter a moisture adjustment to account for the water
evaporation.
• If you are deep-fat or pan-frying an item, the specific frying oil needs to
be treated as a separate ingredient and entered in your list of recipe
ingredients according to the amount absorbed. However, the fried item
Food
will lose moisture as it absorbs fat. This moisture loss needs to be
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entered at this step.
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• Some vitamins are not retained during cooking and storage. The
vitamin losses should be accounted for during this step.
Your production data will inform you how to account for many of these
processing changes. In some cases, you may need laboratory analysis to
provide additional guidance for processing adjustments.
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5
Nutrition Analysis
Step 5:
Set the Serving Size
To determine the Serving Size for the finished Nutrition Facts Panel you
need knowledge about how the product will be packaged and consumed.
In addition, you will need to understand the regulations related to
Serving Size and Reference Amounts Customarily Consumed. Some of
the broad food categories and guidelines for Serving Size are:
• Products with multiple servings that are measured by volume (tsp,
Tbsp, cup) for the serving are labeled by the appropriate volume.
Examples include soups, sauces, condiments, spices, cereals, and
most prepared salads and desserts.
• Single-serve items are labeled as one package, such as an energy bar,
a small bag of potato chips, or a can of soda.
• Products with multiple pieces in a package are divided into servings
based on the number of pieces in a serving. Examples include a bag of
cookies, a loaf of sliced bread, a box of mini-tacos, and a bag of candy
pieces.
• Products sold as a whole but divided into factional pieces are labeled
as the fractional piece, such as a frozen pizza, a cake, or a pie.
Consult the U.S. Code of Federal Regulations at 21 CFR 101.9 and
101.12 for detailed information about Serving Size and Reference
Amounts Customarily Consumed for FDA-regulated foods.
6
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Nutrition Analysis
Step 6:
Perform the Due Diligence Checks
Now that you have the nutrient profile for your finished product on a per
serving basis, you need to perform the due diligence checks to ensure
correct calculations. To ensure your nutrient profile is accurate, you’ll
need to answer “yes” to the following questions:
• Does your spreadsheet report contain a value in every cell?
• Does the total for proximates equal 100%?
• Do the calories make sense in the context of 4-4-9 formula,
Atwater factors, or another FDA-allowed method for calorie calculation?
• Do the fat components (saturated, monounsaturated, polyunsaturated,
trans) make sense in the context of total fat?
• Do the carbohydrate components (dietary fiber, sugars, sugar alcohol,
other carbohydrates) make sense in the context of total carbohydrate?
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The “check data” feature in the Genesis R&D software can help you
validate your nutrition analysis results.
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7
Nutrition Analysis
Step 7:
Apply the Rounding Rules
The nutrition values you publish should be customer-friendly. This means
you should report rounded nutrient values per portion served. FDA has
established specific rounding rules for each nutrient.
Nutrient
Rounding Increments
May Round to Zero…
Calories
nearest 5 calories up to 50 calories;
nearest 10 calories if more than 50
if less than 5 calories
Calories From Fat
nearest 5 calories up to 50 calories;
nearest 10 calories if more than 50
if less than 5 calories
Total Fat
nearest 0.5 gram up to 5 grams;
nearest 1 gram if more than 5 grams
if less than 0.5 gram
Saturated Fat
nearest 0.5 gram up to 5 grams;
nearest 1 gram if more than 5 grams
if less than 0.5 gram
Trans Fat
nearest 0.5 gram up to 5 grams;
nearest 1 gram if more than 5 grams
if less than 0.5 gram
Cholesterol
nearest 5 milligram increment; if between 2 and 5 milligrams, may
report as “less than 5 milligrams”
if less than 2
milligrams
Sodium
nearest 5 milligrams up to 140 milligrams; nearest 10 milligrams
if more than 140 milligrams
if less than 5
milligrams
Carbohydrate
nearest 1 gram; if less than 1 gram,
may report as “less than 1 gram”
if less than 0.5 gram
Dietary Fiber
nearest 1 gram; if less than 1 gram,
may report as “less than 1 gram”
if less than 0.5 gram
Sugars
nearest 1 gram; if less than 1 gram,
may report as “less than 1 gram”
if less than 0.5 gram
Protein
nearest 1 gram; if less than 1 gram,
report as “less than 1 gram”
if less than 0.5 gram
Vitamins/Minerals
nearest 2% increment up to and including the 10% level; nearest 5%
above 10% up to and including the 50%
level; nearest 10% above the 50% level
if less than 2% DV
Reference: 21 CFR 101.9
8
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Nutrition Analysis
Step 8:
Triple-check Your Work
Once your nutrition analysis results are in final form (Nutrition Facts
Panel for a packaged product or a Nutrition Information Guide for a
restaurant menu), make sure your values pass the “common sense” test.
Use your knowledge of food composition to review all nutrient values
again. For example, it makes sense that you would expect to see higher
calories, fat, etc., for a chili cheeseburger than a plain hamburger
assuming the burger and bun sizes are the same.
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Nutrient Content Claims
Use this quick guide to compare your nutrient profiles against common
nutrient content claims for FDA-regulated foods. Be mindful of the many
nuances for claims contained in the U.S. Code of Federal Regulations.
Nutrient Claim
Definition
Low Calorie
40 calories or less per serving
Fat Free
Less than 0.5 gram fat per serving, and includes no
ingredients that contain fat
Low Fat
3 grams or less fat per serving
Main dish/meal: 120 calories or less per 100 grams
Main dish/meal: 3 grams or less fat per 100 grams,
and not more than 30% of calories from fat
Saturated Fat Free Less than 0.5 gram saturated fat and less than 0.5 gram trans fat per
serving, and includes no ingredients that contain saturated fat
Low Saturated Fat 1 gram or less saturated fat per serving, and not more than 15%
of calories from saturated fat
Main dish/meal: 1 gram or less saturated fat per 100 grams,
and less than 10% of calories from saturated fat
Cholesterol Free
Less than 2 milligrams cholesterol and 2 grams or less saturated fat
per serving, and includes no ingredients that contain cholesterol
Low Cholesterol
20 milligrams or less cholesterol, and 2 grams or less saturated fat
per serving
Main dish/meal: 20 milligrams or less cholesterol and 2 grams or less
saturated fat per 100 grams
Salt Free or Sodium Free
Less than 5 milligrams sodium per serving, and does not contain
sodium chloride (table salt) or other sodium-containing ingredients
Very Low Sodium 35 milligrams or less sodium per serving
Main dish/meal: 35 milligrams or less sodium per 100 grams
Low Sodium
140 milligrams or less sodium per serving
Main dish/meal: 140 milligrams or less sodium per 100 grams
(continued on next page)
10
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Lean
Meat, poultry, seafood and game meat with less than 10 grams fat,
4.5 grams or less saturated fat, and less than 95 milligrams cholesterol
per serving and per 100 grams
Extra Lean
Meat, poultry, seafood and game meat with less than 5 grams fat,
less than 2 grams saturated fat, and less than 95 milligrams cholesterol
per serving and per 100 grams
Good Source
Contains Provides
10-19% Daily Value per serving. Example: A good source of
iron contains between 1.8 and 3.4 milligrams iron per serving.
Excellent Source 20% or more Daily Value per serving. Example: An excellent
High in
source of fiber contains 5 grams or more fiber per serving.
Rich in
Reduced
Lower
A nutritionally-altered food that contains at least 25% less of a
nutrient than a reference food
Light or Lite
A nutritionally-altered food that contains at least 1/3 fewer calories or
50% less fat than the higher-calorie, higher-fat version
Healthy
A food that is low in fat and saturated fat, contains 480
milligrams or less sodium per serving, and provides at least
10% Daily Value for one of these nutrients: Vitamin A,
Vitamin C, calcium, iron, protein and fiber
Notes:
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• Per serving is a reference amount of more than 30 grams or more than 2 tablespoons.
Different criteria apply for smaller reference amounts.
• Main dishes weigh at least 6 ounces per serving, contain not less than 40 grams each of at least
two different foods from at least two specified food groups, and are represented as a main dish.
• Meals weigh at least 10 ounces per serving, contain not less than 40 grams each of at least
three different foods from at least two specified food groups, and are represented as a meal.
Reference: 21 CFR 101.9, 101.13, and 101.54-65
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11
Additional Resources
To help you in your quest for accurate nutrition analysis, here are some
additional resources:
• Subscribe to Food Label News, a free monthly e-newsletter including
topics of interest to food labelers and answers to reader questions:
www.foodlabelnews.com/subscribe
• Request the free one-pager with rules of thumb used by Food
Consulting Company; enter “rules of thumb” in the Comments box:
www.foodlabels.com/contact
• Join the discussion about topics of interest to food
labelers on LinkedIn’s Food Label Community:
www.foodlabels.com/linkedin/community
• Register for a Genesis R&D training session:
www.esha.com/training
About Food Consulting Company
Food Consulting Company, founded in 1993, provides nutrition analysis,
food labeling and regulatory support to ensure compliance for products
sold in North America (U.S., Canada and Mexico) and Europe. With
over 1,500 clients worldwide, Food Consulting Company is the largest
outsource provider of these services for manufacturers, distributors,
importers, and restaurateurs — from start-ups to Fortune 50 companies
like PepsiCo and Target.
Since 1998, Food Consulting Company has partnered with ESHA
Research to conduct intensive training for Genesis R&D, the food
industry’s leading nutrition analysis software. Having conducted
hundreds of training sessions, Food Consulting Company continues
to provide insights on topics important to food labeling and accurate
nutrition analysis.
12
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Food
Consulting
Company
Nutrition • Labeling • Regulatory
www.foodlabels.com
[email protected]
13724 Recuerdo Drive
Del Mar, CA 92014 USA
tel 800.793.2844
fax 800.522.3545