21 CFR 101.54 defines the nutrient content claims that characterize a food as a good, high, or enhanced source of a beneficial nutrient — including vitamins, minerals, dietary fiber, and protein. These are among the most commonly used claims on food and supplement labels, and they carry specific % Daily Value (DV) requirements that must be met before the claim can legally appear on a label.
"Good Source" Claims
Under 21 CFR 101.54(c), the following terms may be used when a food contains 10% to 19% of the DV for the nutrient per RACC:
"Good source of [nutrient]"
"Contains [nutrient]"
"Provides [nutrient]"
Examples: "Good source of calcium," "Contains vitamin D," "Provides iron."
The 10% DV threshold applies to the per-RACC amount — not the per-serving amount if those differ, though in practice they are often the same.
"High," "Rich in," and "Excellent Source" Claims
Under 21 CFR 101.54(b), the following terms may be used when a food contains 20% or more of the DV for the nutrient per RACC:
"High in [nutrient]"
"Rich in [nutrient]"
"Excellent source of [nutrient]"
Examples: "High in protein," "Excellent source of vitamin C," "Rich in calcium."
This 20% DV threshold is the standard for "excellent source" claims on mainstream food and supplement labels — including the "high protein" claims common on supplement products.
"More," "Added," and "Extra" Claims — Relative Claims
Under 21 CFR 101.54(e), "more," "added," "plus," "extra," "fortified," or "enriched" claims may be used when a food contains at least 10% more of the DV for a nutrient per RACC than an appropriate reference food.
These are relative claims — the product must have more of the nutrient than the reference food, and the label must identify the reference food and state the percentage difference.
Example: "More fiber — contains 3 g more fiber per serving than [reference product]"
Summary of Thresholds
Claim | DV Threshold | Type |
|---|---|---|
Good source / Contains / Provides | 10–19% DV | Absolute |
High / Rich in / Excellent source | ≥ 20% DV | Absolute |
More / Added / Fortified / Enriched | ≥ 10% more DV than reference | Relative |
Nutrients Covered
21 CFR 101.54 applies to nutrients that have established Daily Values under 21 CFR 101.9 and 21 CFR 101.36. Common nutrients covered:
Vitamins: A, C, D, E, K, B vitamins (B6, B12, folate, thiamin, riboflavin, niacin, pantothenic acid, biotin)
Minerals: calcium, iron, potassium, phosphorus, magnesium, zinc, selenium, manganese, chromium, molybdenum, iodine, copper
Dietary fiber
Protein (subject to PDCAAS-based requirements — see below)
Nutrients without an established DV (such as most non-essential amino acids, phytochemicals, or novel ingredients) cannot be the subject of a "good source" or "high" claim.
Protein Claims: PDCAAS Requirement
Protein content claims are subject to an additional requirement. Under 21 CFR 101.9(c)(7)(ii), for a food to bear a "high protein" claim, the protein's quality must be assessed using the Protein Digestibility Corrected Amino Acid Score (PDCAAS). The PDCAAS-adjusted protein value per serving must meet the 20% DV threshold.
A product with 20 g of protein per serving from a low-quality protein source with a low PDCAAS score may not qualify for a "high protein" or "excellent source of protein" claim, even though it contains significant protein by weight.
Interaction with Disqualifying Nutrients
Under 21 CFR 101.13(h), "good source" and "high" claims may trigger a mandatory disclosure statement if the food contains more than specified levels of disqualifying nutrients:
Nutrient | Disclosure Trigger |
|---|---|
Total fat | > 13 g per RACC and per 50 g |
Saturated fat | > 4 g per RACC and per 50 g |
Cholesterol | > 60 mg per RACC and per 50 g |
Sodium | > 480 mg per RACC and per 50 g |
If any threshold is exceeded, the label must direct consumers to the Nutrition Facts panel (e.g., "See back panel for fat content").
Application to Dietary Supplements
"Good source," "high," and "excellent source" claims are used extensively on dietary supplement labels — particularly for:
Vitamin/mineral supplements ("Excellent source of vitamin D")
Protein supplements ("High protein," "30g protein per serving")
Fiber supplements ("Good source of dietary fiber")
Fortified nutrition bars ("High in B vitamins")
The same 21 CFR 101.54 thresholds apply. A supplement claiming to be a "good source" of a vitamin must contain 10–19% DV per serving, and "high" or "excellent source" must contain ≥ 20% DV.
How Truli Helps with Good Source and High Claims
DV threshold verification: Truli calculates the % DV for each nutrient per serving and flags "good source" claims that fall below 10% DV or "high"/"excellent source" claims that fall below 20% DV
Relative claim documentation: Truli verifies that "more," "added," or "fortified" claims include the required reference food identification and percentage difference disclosure
Protein PDCAAS check: Truli flags "high protein" claims where the protein source quality may not support the claim after PDCAAS adjustment
Disqualifying nutrient disclosure: Truli identifies foods bearing "good source" or "high" claims that also contain disqualifying levels of fat, saturated fat, cholesterol, or sodium and need a disclosure statement
Related Regulations
21 CFR 101.13 — Nutrient Content Claims — General principles for all nutrient content claims
21 CFR 101.9 — Nutrition Facts Panel — % DV values that determine claim eligibility
21 CFR 101.36 — Supplement Facts Panel — % DV declarations on supplement labels
21 CFR 101.60 — Calorie Content Claims — Calorie claim thresholds
Frequently Asked Questions
Our protein bar has 25 g protein per serving — does that automatically qualify for "high protein"?
Not automatically. The protein DV is 50 g, so 25 g is 50% DV — that would meet the ≥ 20% DV threshold. However, you must also verify that the protein quality (PDCAAS score) does not reduce the qualifying amount below 20% DV when adjusted for protein digestibility. Most complete protein sources (whey, soy, egg) have high PDCAAS scores; plant proteins with incomplete amino acid profiles may score lower.
Can we use "contains vitamin C" on a product with only 8% DV vitamin C?
No. "Contains [nutrient]" is one of the synonyms for "good source" under 21 CFR 101.54(c) and requires 10–19% DV. At 8% DV, the product does not qualify for this claim.
We fortified our product with additional calcium to boost its DV% — does the fortified calcium count?
Yes, the Nutrition Facts panel reflects the total calcium from all sources (naturally occurring plus added), and the % DV calculation for claim purposes is based on the labeled value. Fortification to reach a "good source" or "high" threshold is common and permissible, provided the formulation is accurate and stable.
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 101.54 as of April 2026. Book a demo to see how Truli monitors food label compliance.
