21 CFR 101.56 defines "light" and "lite" as nutrient content claims on food labels. These terms are regulated — a food cannot bear a "light" claim simply because it seems lighter in flavor, texture, or color. "Light" must be based on a measurable nutrient reduction relative to an appropriate reference food.
The Bases for "Light" Claims
A food may be labeled "light," "lite," "lightly," or related terms on one of the following bases, depending on the food's fat calorie composition:
1. Fat-Based "Light" — High-Fat Foods (≥ 50% Calories from Fat)
If a food derives 50 percent or more of its calories from fat, the "light" claim requires:
At least 50% reduction in fat per RACC compared to the reference food
Disclosure of both the reference food and the fat reduction amount/percentage
Example: Light sour cream — since regular sour cream derives more than 50% of its calories from fat, a "light" version must contain ≥ 50% less fat per serving than the reference sour cream.
2. Calorie-Based "Light" — Lower-Fat Foods (< 50% Calories from Fat)
If a food derives less than 50% of its calories from fat, the "light" claim may be based on either:
At least one-third fewer calories per RACC compared to the reference food, or
At least 50% less fat per RACC compared to the reference food
Disclosure of both the reference food and the applicable reduction (calorie or fat, whichever is the basis) is required.
Example: Light bread — regular bread derives less than 50% of its calories from fat, so a "light" version must have at least 1/3 fewer calories per serving (or at least 50% less fat) compared to regular bread of the same type.
3. Sodium-Based "Light"
For a "light in sodium" or "lightly salted" claim:
The food must contain at least 50% less sodium per RACC than the reference food
The basis of the claim ("light in sodium") must be clearly identified
The label must also state "not a low sodium food" if the food does not qualify as low sodium (≤ 140 mg per serving)
Required Disclosure: The Basis of the Claim
Under 21 CFR 101.56(b)(4), when "light" is used for a claim that is not self-evident (e.g., "light in sodium" on a product that consumers might assume is "light" in calories), the label must specify the basis of the claim:
"Light in sodium"
"Light in calories"
"Light in fat"
If a product qualifies for "light" on both a calorie and fat basis, it may simply say "light" without specifying. If it qualifies only on one basis, the specific basis should be stated to prevent consumer confusion.
Reference Food Requirements
The comparison for a "light" claim must be to an appropriate reference food:
The same food made by the same manufacturer in a regular version, or
The average of the top three brands of the same product category in the marketplace
The reference food and comparison values must be disclosed on the label adjacent to the "light" claim. Example: "Light — 33% fewer calories than Original [Brand Name]" or "50% less fat than regular cream cheese."
Summary of "Light" Claim Thresholds
Claim Basis | Threshold | Disclosure Required |
|---|---|---|
Fat (food ≥ 50% fat calories) | ≥ 50% less fat vs. reference | Reference food + fat reduction |
Calorie or fat (food < 50% fat calories) | ≥ 1/3 fewer calories vs. reference, OR ≥ 50% less fat vs. reference | Reference food + % reduction |
Sodium | ≥ 50% less sodium vs. reference | Reference food + sodium reduction; "not a low sodium food" if applicable |
"Lightly Salted"
Under 21 CFR 101.56(b)(3), "lightly salted" may be used when:
The food contains at least 50% less sodium than the comparable reference food
A statement appears on the label: "Not a low sodium food" — if the food does not meet the ≤ 140 mg per serving threshold for "low sodium"
"Lightly salted" is distinct from "no salt added" (which is a process claim — no salt added during manufacturing) and from "low sodium" (which is an absolute threshold claim). A "lightly salted" product may still contain significant sodium; the claim only indicates a 50% reduction relative to the regular version.
Descriptive Use of "Light" Without a Nutrient Claim
"Light" in purely descriptive, non-nutrient contexts — such as describing flavor, color, or texture — is permissible as long as it clearly does not imply a nutrient reduction. Examples:
"Light golden color" — describing appearance
"Light flavor" — describing taste intensity
"Light texture" — describing physical properties
If the context makes clear that "light" refers to a sensory characteristic rather than a nutrient level, it is not treated as a nutrient content claim. However, if the word "light" appears prominently on the label in a way that consumers might reasonably interpret as a nutrient claim, FDA will evaluate whether the claim thresholds are met.
How Truli Helps with "Light" Claim Compliance
Reference food identification: Truli identifies appropriate reference foods for "light" claim comparisons and verifies that the claimed reduction meets the applicable threshold
Claim basis disclosure check: Truli verifies that "light" labels specify the basis of the claim when it is not self-evident, and that reference food and percentage reduction disclosures are present
"Lightly salted" disclosure: Truli checks whether "lightly salted" products include the required "not a low sodium food" disclosure when applicable
Contextual "light" assessment: Truli evaluates uses of "light" or "lite" on labels in context to determine whether they function as nutrient content claims or purely descriptive terms
Related Regulations
21 CFR 101.13 — Nutrient Content Claims — General principles for nutrient content claims
21 CFR 101.60 — Calorie Content Claims — Absolute calorie claim thresholds (calorie free, low calorie)
21 CFR 101.61 — Sodium Content Claims — Absolute sodium claim thresholds and "no salt added"
21 CFR 101.62 — Fat Content Claims — Absolute fat claim thresholds (fat free, low fat)
Frequently Asked Questions
Our product is called "Lite Ranch Dressing." Does the product name constitute a nutrient content claim?
Yes — "Lite" in a product name is a nutrient content claim if consumers would reasonably interpret it as indicating a reduced nutrient level. "Lite Ranch Dressing" would be evaluated against the 21 CFR 101.56 thresholds. If regular ranch dressing derives 50% or more of its calories from fat, "Lite Ranch Dressing" must contain at least 50% less fat than the reference food. If the product doesn't meet that threshold, the name is a misbranding violation.
Can we say "light" if we only reduced the sodium by 30%?
No. "Light in sodium" or "lightly salted" requires a 50% reduction in sodium compared to the reference food. A 30% reduction does not meet the threshold. You could potentially use "reduced sodium" (21 CFR 101.61), which requires only a 25% reduction — but not "light" or "lightly salted."
We replaced sugar with a non-caloric sweetener, which reduced calories by 40%. Can we say "light"?
If the food derives 50% or less of its calories from fat (most sweetened foods do), the threshold for "light" on a calorie basis is 1/3 fewer calories — which is approximately 33%. A 40% calorie reduction exceeds the 1/3 threshold, so "light" would be permissible if the calorie comparison is made against an appropriate reference food and the required disclosure is included.
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 101.56 as of April 2026. Book a demo to see how Truli monitors food label compliance.
