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21 CFR 101.12 establishes reference amounts customarily consumed (RACCs) for food categories — standardized amounts that represent how much of a food is typically consumed per eating occasion. RACCs are the regulatory foundation for:

• Serving sizes on the Nutrition Facts panel (21 CFR 101.9)

• Nutrient content claim eligibility (claims are evaluated per RACC, not per arbitrary serving size)

• Health claim eligibility (many authorized health claims require specific nutrient levels per RACC)

What Is a RACC?

A RACC is the amount of food typically consumed per eating occasion by a person 4 years old or older, as determined by FDA from dietary intake surveys. RACCs are set in metric units (grams or milliliters).

RACCs are established per food category — not per individual product. A brand must identify which FDA food category applies to its product and use the RACC for that category.

Examples of common RACCs:

How the RACC Determines the Labeled Serving Size

Under 21 CFR 101.9(b), the labeled serving size on the Nutrition Facts panel must be expressed in common household measures and must equal the RACC for the product's food category, except:

• If the product comes in a single-serving container (the entire content is reasonably consumed in one sitting), the serving size is the entire container

• If one unit equals the RACC or falls within 1/2 to 2 times the RACC, the labeled serving may equal one unit

• If the RACC falls between household measure amounts, the labeled serving is the household measure closest to the RACC

Important: A brand cannot declare an arbitrary serving size that is significantly smaller than the RACC to make the nutrition profile appear better. The serving size must track the RACC for the applicable category.

The 2016 RACC Updates

FDA updated many RACCs in 2016 as part of the Nutrition Facts panel modernization. Key changes that affected supplement and food brands:

• Ice cream: RACC increased from 1/2 cup to 2/3 cup (reflecting actual consumption)

• Soda: RACC clarified for typical consumption patterns

• Products consumed in one sitting: New single-serving container rule for products between 200–300% of RACC (these get dual-column Nutrition Facts panels showing per serving and per container values)

RACCs for Dietary Supplements

Dietary supplements do not use the same RACC framework as conventional foods. Under 21 CFR 101.36, the serving size for dietary supplements is determined by:

• Unit dose products (tablets, capsules, softgels): The labeled serving size is the number of units recommended per day or per eating occasion

• Powders and liquids: The recommended use amount per occasion

For supplements, the "RACC" concept from 21 CFR 101.12 applies primarily when evaluating whether a supplement product is actually a conventional food (e.g., a protein bar or nutrition shake) and which labeling format (Nutrition Facts vs. Supplement Facts) applies.

RACCs and Nutrient Content Claims

Nutrient content claims under 21 CFR 101.54–101.67 are evaluated per RACC and per labeled serving. The RACC, not the labeled serving size, is the critical measurement unit for determining claim eligibility:

• A product cannot qualify for a "low fat" claim by declaring an artificially small serving size if the RACC for that product category requires a larger serving

• FDA evaluates claims against both the per-RACC amount and the per-labeled-serving amount; both must meet the threshold

For products with a RACC of 30 g or less or 2 tablespoons or less, claims are also evaluated per 50 g — the "per 50 g" threshold prevents claims on very concentrated products that appear to meet criteria only because of extremely small serving sizes.

What If No RACC Exists for My Product?

If a product does not fit neatly into one of the food categories in 21 CFR 101.12, brands should:

1. Identify the most similar food category and use that RACC

2. Consider whether the product is a new food category that may warrant a RACC petition to FDA

3. For novel foods or dietary supplements, FDA guidance on the appropriate serving size should be followed

Brands that cannot identify a closely applicable RACC should consult FDA guidance documents or seek regulatory counsel.

How Truli Helps with RACC and Serving Size Compliance

• RACC category identification: Truli matches food products to the appropriate 21 CFR 101.12 food category and verifies that the labeled serving size aligns with the applicable RACC

• Claim eligibility recalculation: Truli recalculates nutrient content claim eligibility against the correct RACC when a product may have been using an incorrect serving size as the basis for claims

• Dual-column trigger assessment: Truli evaluates whether a product's serving size and package content fall within the range that requires a dual-column Nutrition Facts format (between 200–300% of RACC)

Related Regulations

• 21 CFR Part 101 — FDA food labeling overview

• 21 CFR 101.9 — Nutrition Facts Panel — How RACC translates to the labeled serving size

• 21 CFR 101.13 — Nutrient Content Claims — How claims are evaluated per RACC

• 21 CFR 101.54 — Good Source, High, and More Claims — RACC-based DV thresholds for beneficial nutrient claims

Frequently Asked Questions

Can we declare a smaller serving size than the RACC to make our product look healthier?
No. Under 21 CFR 101.9(b), the labeled serving size must be based on the RACC for the applicable food category. FDA has specifically addressed this issue — brands may not manipulate serving sizes to make nutrient profiles appear more favorable than they are. A serving size materially smaller than the applicable RACC is a misbranding violation.

Our product is a meal replacement shake — which RACC applies?
Meal replacement products may fall under "meal replacements, powders and mixes" or "beverages, meal replacements" depending on form. The applicable category determines the RACC. If the product meets the criteria for a dietary supplement (takes a Supplement Facts panel), serving size is determined under 21 CFR 101.36 rather than 21 CFR 101.12.

The RACC for my category is 30 g but my standard portion is 60 g. What do I declare?
If your product is commonly consumed in 60 g portions (close to 2× the RACC) and one 60 g unit is a natural portion, you may be able to declare 60 g as the serving size — within the 1/2 to 2× RACC range that allows unit-based serving sizes. However, if the 30 g RACC is the applicable category standard and your 60 g portion doesn't correspond to a natural unit, the labeled serving should be closer to 30 g.

A note from Truli: Truli is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.

Last updated: April 2026. Reflects 21 CFR 101.12 as updated in 2016 and effective January 1, 2020. Book a demo to see how Truli monitors food label compliance.