Healthy Claim Food Groups: FDA Criteria by Category
Healthy claim food groups explained with FDA criteria for food group equivalents, added sugars, sodium and saturated fat by product category.
FDA healthy claim food groups determine which minimum food group equivalent and maximum added sugars, sodium and saturated fat limits your product must meet to use a "healthy" claim. Which four numbers apply depends on the category your food falls into, and those categories are established in 21 CFR 101.65(d), not by a general summary of the rule.
This article is a category-by-category lookup for formulators and label reviewers who have already decided they want to use the claim. Find the row that describes your product, identify the applicable food group equivalent and nutrient limits, then compare them with your formulation and specification data.
If you are still deciding whether to make the claim, start with FDA healthy claim requirements, which explains what changed from the 1994 definition. For a yes-or-no walkthrough of one product, see can my food be labeled healthy. Products that avoid the arithmetic entirely are covered in foods that automatically qualify as healthy.
FDA healthy criteria status: final rule, voluntary claim, 25 February 2028
The rule "Food Labeling: Nutrient Content Claims; Definition of Term 'Healthy'" was published at 89 FR 106064 on 27 December 2024 under docket FDA-2016-D-2335.
Its effective date as originally published was 25 February 2025. A Federal Register notice issued under the January 2025 regulatory freeze delayed that date to 28 April 2025. The compliance date did not change and remains 25 February 2028.
The claim is voluntary. Nothing requires you to describe a food as "healthy." Starting 25 February 2028, however, a product using the word in a nutritional context must meet the criteria below.
You may adopt the updated criteria today. If you are already redesigning packaging, applying the new criteria now can avoid another artwork revision later.
Under 101.65(d)(3), the covered terms are healthy, health, healthful, healthfully, healthfulness, healthier, healthiest, healthily and healthiness.
Step one: identify which healthy claim food group table applies
There are four routes through the FDA healthy claim criteria. Work through them in order and stop at the first one that applies.
- Automatic qualifier. Is the product made only from qualifying whole foods with nothing added except water, or is it water, plain tea or plain coffee under 5 calories? If so, it automatically qualifies and you do not need the nutrient-limit calculation.
- Individual food. Is it a single food fitting one of the twelve individual categories below? Use the individual foods table, applying the criteria per RACC or per 50 g depending on the RACC.
- Mixed product. Does it combine food groups without qualifying as a main dish or meal, such as a soup, bar or yogurt with fruit? Use the mixed-product criteria per RACC.
- Main dish or meal. Does it meet the definition of a main dish under 21 CFR 101.13(m) or a meal under 101.13(l)? Use the applicable row and test it per labeled serving.
The distinction between an individual food and a mixed product causes particular confusion.
A plain canned bean is an individual food. A bean and vegetable chili is a mixed product because it obtains food group equivalents from more than one food group.
Food group equivalents: what counts as one FGE
Every category criterion below uses food group equivalents, or FGE. The rule defines one FGE for each of the FDA healthy claim food groups in Table 1 at 101.65(d)(2) and provides worked examples.
These are the units you use when converting your recipe into the food group amounts required by the healthy claim criteria.
| Food group | One food group equivalent | Examples given in the rule |
|---|---|---|
| Vegetable | 1/2 cup equivalent | 1/2 cup cooked green beans; 1 cup raw spinach |
| Fruit | 1/2 cup equivalent | 1/2 cup strawberries; 1/2 cup 100% orange juice; 1/4 cup raisins |
| Grains | 3/4 oz equivalent whole grain | 1 slice bread; 1/2 cup cooked brown rice |
| Dairy | 2/3 cup equivalent | 2/3 cup fat-free milk; 1 oz nonfat cheese |
| Protein foods: game meat | 1 1/2 oz equivalent | 1 1/2 oz venison |
| Protein foods: seafood | 1 oz equivalent | 1 oz tuna |
| Protein foods: egg | 1 oz equivalent | 1 large egg |
| Protein foods: beans, peas, lentils | 1 oz equivalent | 1/4 cup black beans |
| Protein foods: nuts, seeds, soy products | 1 oz equivalent | 1/2 oz walnuts |
The dairy figure changed during rulemaking. FDA proposed a 3/4 cup equivalent but finalized a 2/3 cup equivalent, which is why some older summaries still show the larger amount.
One ounce of natural cheese, or 2/3 ounce of processed cheese, also counts as one 2/3 cup equivalent of dairy.
Foods that automatically meet the healthy claim criteria
Some foods do not need to be tested against the nutrient limits.
Under 101.65(d)(3)(i) and (vi), if the food consists only of the qualifying ingredients below, with nothing added except water, it qualifies without going through the nutrient-limit calculation.
| Automatic qualifier | Condition |
|---|---|
| Vegetables, fruit, whole grains | Fresh, frozen, canned or dried forms all count, provided nothing but water is added |
| Fat-free or low-fat dairy | No added ingredients other than water |
| Lean meat, seafood, eggs, beans, peas, lentils, nuts, seeds | No added ingredients other than water |
| A mixed product made only of the items above | One or more of those foods and nothing else except water |
| Water, tea and coffee | Less than 5 calories per RACC and per labelled serving |
FDA's examples of foods that newly qualify under the 2024 rule include water, avocados, nuts and seeds, higher-fat fish such as salmon, olive oil, certain peanut butters and certain canned fruits and vegetables.
FDA's examples of foods that no longer qualify include fortified white bread, highly sweetened yogurt and highly sweetened cereal.
The added ingredient that most commonly eliminates automatic qualification is salt.
Healthy claim criteria for the twelve individual food categories
This is the main category table for the FDA healthy criteria. It comes from 101.65(d)(3)(ii), Tables 2 and 3.
The regulation expresses each nutrient limit as a percentage of the Daily Value. The gram and milligram figures in brackets are those percentages applied to the adult Daily Values of 50 g added sugars, 2,300 mg sodium and 20 g saturated fat, which is also how FDA's preamble expresses them.
| Category | Must contain at least | Added sugars max | Sodium max | Saturated fat max |
|---|---|---|---|---|
| Vegetable product | 1/2 cup-eq vegetable | 2% DV (1 g) | 10% DV (230 mg) | 5% DV (1 g) |
| Fruit product | 1/2 cup-eq fruit | 2% DV (1 g) | 10% DV (230 mg) | 5% DV (1 g) |
| Grain product | 3/4 oz-eq whole grain | 10% DV (5 g) | 10% DV (230 mg) | 5% DV (1 g) |
| Dairy product | 2/3 cup-eq dairy | 5% DV (2.5 g) | 10% DV (230 mg) | 10% DV (2 g) |
| Game meats | 1 1/2 oz-eq | 2% DV (1 g) | 10% DV (230 mg) | 10% DV (2 g) |
| Seafood | 1 oz-eq | 2% DV (1 g) | 10% DV (230 mg) | 5% DV (1 g), excluding saturated fat inherent in seafood |
| Egg | 1 oz-eq | 2% DV (1 g) | 10% DV (230 mg) | 10% DV (2 g) |
| Beans, peas, lentils | 1 oz-eq | 2% DV (1 g) | 10% DV (230 mg) | 5% DV (1 g) |
| Nuts, seeds, soy products | 1 oz-eq | 2% DV (1 g) | 10% DV (230 mg) | 5% DV (1 g), excluding saturated fat inherent in nuts, seeds and soybeans |
| 100% oil | Not applicable | 0% DV | 0% DV | 20% of total fat |
| Oil-based spread (fats solely from oil) | Not applicable | 0% DV | 10% DV (230 mg) | 20% of total fat |
| Oil-based dressing (at least 30% oil, oils meeting the oil criteria) | Not applicable | 2% DV (1 g) | 10% DV (230 mg) | 20% of total fat |
Three differences between the categories are particularly important.
First, the sodium ceiling is 230 mg for every category except 100% oil, which must contain no sodium at all.
Second, added sugars vary substantially by category. A grain product can contain up to 5 g, a dairy product up to 2.5 g, while almost every other individual category is limited to 1 g.
Third, the three oil categories do not use a percentage of the Daily Value as an absolute saturated fat limit. Instead, saturated fat cannot exceed 20% of the product's total fat. This is a ratio test rather than an absolute gram limit, and it is why olive oil qualifies while coconut oil does not.
Two inherent-fat exclusions also matter. For seafood, and for nuts, seeds and soybeans, the saturated fat naturally present in the food itself is excluded from the calculation. Only added saturated fat counts.
That exclusion allows foods such as salmon and walnuts to satisfy a 1 g ceiling they would otherwise fail based on their natural composition. If you add butter or a coconut oil coating, however, the saturated fat from those added ingredients counts.
FDA healthy claim criteria per RACC or per 50 g
The individual-food criteria use one of two calculation bases. Choosing the wrong basis can produce the wrong answer in either direction.
If your product's RACC is greater than 50 g, or greater than 3 tablespoons, apply the criteria per RACC.
If the RACC is 50 g or less, or 3 tablespoons or less, apply the criteria per 50 g of product.
Consider cookies and snack crackers. Both have a 30 g RACC, which is below the threshold, so they are tested per 50 g rather than per 30 g serving.
In practice, that means multiplying the per-serving figures on the Nutrition Facts panel by 1.67 before comparing them with the 230 mg sodium ceiling.
A cracker declaring 150 mg sodium per 30 g serving contains 250 mg per 50 g and therefore fails the limit, even though the number printed on the Nutrition Facts panel is below 230 mg.
Breads and rolls, at 50 g, are on the boundary and are also tested per 50 g. Bagels and muffins, at 110 g, are tested per RACC.
If you are unsure which reference amount applies to your product, our RACC lookup provides the current 21 CFR 101.12 values.
Healthy claim food groups for mixed products, main dishes and meals
The criteria for mixed products, main dishes and meals come from 101.65(d)(3)(iii) through (v).
In every row, the saturated fat maximum excludes saturated fat inherent in seafood, nuts, seeds and soy products, using the same carve-out that applies to the corresponding individual-food categories.
| Type | Must contain | Added sugars max | Sodium max | Saturated fat max |
|---|---|---|---|---|
| Mixed product, per RACC | 1 total FGE, with at least 1/4 FGE from each of at least 2 food groups | 10% DV (5 g) | 15% DV (345 mg) | 10% DV (2 g) |
| Main dish, per labelled serving, as defined in 101.13(m) | 2 total FGE, with at least 1/2 FGE from each of at least 2 food groups | 15% DV (7.5 g) | 20% DV (460 mg) | 15% DV (3 g) |
| Meal product, per labelled serving, as defined in 101.13(l) | 3 total FGE, with at least 1/2 FGE from each of at least 3 food groups | 20% DV (10 g) | 30% DV (690 mg) | 20% DV (4 g) |
The calculation basis changes between these categories.
Mixed products are tested per RACC, like individual foods. Main dishes and meals are tested per labeled serving, meaning the amount you actually declare as the serving on the Nutrition Facts panel.
For a frozen entree sold as one serving, for example, the whole tray is tested. A meal is therefore assessed as the portion a person eats rather than against a reference amount.
Whether your product is a main dish or meal is not a judgment call. Both terms are defined in 101.13(m) and 101.13(l), so confirm the applicable definition before assuming your product qualifies for the more generous meal criteria.
Where FDA's consumer page and CFR healthy claim criteria disagree
FDA's consumer-facing page about the term "healthy" summarizes the individual-food limits as 2.5 g added sugars, 230 mg sodium and 2 g saturated fat. It summarizes mixed products as 5 g, 345 mg and 2 g, and meals as 10 g, 690 mg and 4 g.
Compared with the CFR tables above, two parts of that summary do not align across all individual food categories.
The consumer page gives 2.5 g added sugars for individual foods, which is the dairy limit. Most individual categories are limited to 2% DV, or 1 g, while grain products can contain 10% DV, or 5 g.
The consumer page also gives 2 g saturated fat for individual foods, which applies to dairy, game meat and egg products. Vegetable, fruit, grain, seafood, bean, nut and seed products are limited to 5% DV, or 1 g. The consumer summary also does not include a separate main dish row.
For product formulation and label review, use the CFR tables. The consumer page is a plain-language summary for shoppers, while 101.65(d) contains the category-specific regulatory criteria.
If you need to test one product, our claim validator uses the CFR figures rather than the consumer summary figures.
Frequently asked questions about healthy claim food groups
My product is a granola bar with oats, almonds and dried cranberries. Which row applies?
A mixed product, in almost every case. It draws food group equivalents from grains, nuts and fruit, so it is tested against 1 total FGE with at least 1/4 FGE from at least two of those groups, plus limits of 5 g added sugars, 345 mg sodium and 2 g saturated fat per RACC. Saturated fat inherent in the almonds is excluded, while added coconut oil, chocolate coating or palm fat counts.
My RACC is 30 g. Do I test per serving or per 50 g?
Per 50 g. A product with a RACC of 50 g or less, or 3 tablespoons or less, is tested on a 50 g basis. You therefore need to scale the per-serving nutrient values before comparing them with the healthy claim limits. This particularly affects crackers, cookies, chips and other snack products whose Nutrition Facts serving is smaller than 50 g.
Does saturated fat from fish or nuts count against the healthy claim limit?
No, when that saturated fat is inherent in the qualifying ingredient. Saturated fat naturally present in seafood, nuts, seeds and soybeans is excluded in the applicable individual-food rows and in the mixed product, main dish and meal rows. Saturated fat added through oils, dairy fat or coatings still counts. This exclusion allows foods such as salmon, almonds and nut butters to qualify under the 2024 definition.
What records do I need to keep if I make a healthy claim?
Under 101.65(d)(4), you must keep written records verifying the product's food group equivalent content, such as recipes, formulations, database analyses or batch records, for at least two years after the food enters interstate commerce. You must provide them to FDA on request during an inspection. The exception applies where FGE content is evident from the label itself or the food automatically qualifies.
If you are reformulating to meet one of these category rows, build the panel and check the nutrient values before the artwork goes to print. Our nutrition label generator produces a compliant Nutrition Facts panel from your recipe, and the claim validator tests the result against the 101.65(d) criteria for the category you select.
