The sugar terminology debate: your regulator has already answered it

Published in Global Perspectives on Nutrition in April and led by Jennie Brand-Miller with a group of Australian co-authors, it argues that the way we classify sugars no longer has a scientific rationale. Added. Free. Intrinsic. Extrinsic. Non-milk extrinsic. The paper argues that these categories are historical accidents rather than science, and that they should be relegated to history.

It’s controversial. The authors say so themselves, in the paper.

Here’s my take. I agree with a lot of it.

We have too many words for the same thing

Glucose is glucose. Sucrose is sucrose. The molecule does not change depending on which committee named it.

Nutrition science doesn’t do this to anything else. There is no such thing as free starch. Nobody distinguishes intrinsic from extrinsic fat, even though olive oil is pressed from fruit and sits at the centre of the diet we hold up as the healthiest on the planet. Sugars alone carry a vocabulary that grew by accretion, one authority at a time, each one solving a communication problem that no longer exists.

The result is five words for a thing that consumers understand as one word.

The distinction that actually matters isn’t the jargon

What people need to understand is the difference between the sugar in a piece of fruit and the sugar in a soft drink. That’s it. That’s the distinction with consequences attached.

The paper argues that the consistent harm signal sits with sugar-sweetened beverages rather than sugars generally, and points to liquid form, lower satiety and frequency of intake as the likely reasons. Whether you accept that framing in full or not, the underlying observation is hard to argue with. A shopper standing in front of a shelf does not need a taxonomy. They need to know which product is which.

I don’t mind what we call it. But it has to be clearer than it is now.

Sometimes a little sugar earns its place

The other point I agree with is the one the industry has been making quietly for years.

If adding a small amount of sugar gets people eating more of the good stuff, the fibre-rich cereal, the yoghurt, the wholegrain biscuit, then I want them to eat it. The sugar is not the enemy in that product. It’s what makes the fibre, the calcium, and the wholegrain palatable enough to become a habit.

A reformulation that strips sugar out and takes the consumer with it hasn’t improved anyone’s diet.

Where I’d add a caveat

This is a Perspective, not evidence. Several of the authors have industry or commercial associations, all of them declared in the paper.

I don’t raise that to dismiss the argument. I raise it because it is precisely the problem. The moment a paper like this lands, the response is filed according to who wrote it rather than what it says, and the debate stops being about sugars and starts being about motives. That reflex costs us more than it protects us.

Nutrition is a young science, and that’s okay

We should give nutrition some grace. We are a few decades into seriously studying how food behaves in the human body, and we haven’t landed on perfect terminology yet. Fields far older than ours have revised their vocabulary more than once.

But when we do settle on definitions, everyone has to be in the room.

Terminology cannot be invented by public health and then rejected by industry. That divide is exactly what confuses consumers, because it produces two competing vocabularies on the same shelf and leaves the shopper to arbitrate between them.

The Health Star Rating is what happens when we don’t agree. A system designed to simplify, still voluntary, still argued over more than a decade in, still applied unevenly across categories. Not because the concept was wrong, but because the agreement was never complete.

What the Food Standards Code actually says right now

Here’s where this stops being a debate and starts being a labelling decision.

Your nutrition information panel declares sugars. Not added, not free. Section 1.2.8-6 requires the average quantity of protein, carbohydrate, sugars, fat and saturated fatty acids per serving and per unit quantity, and for the purposes of Standard 1.2.7, Standard 1.2.8 and Schedule 4, sugars means monosaccharides other than D-allulose, plus disaccharides. Every one of them, from whatever source, is reported as a single figure. That has not changed.

Under Proposal P1062, the Code does now contain a definition of added sugars, but it exists for one purpose only: nutrition content claims. The revised entry in the Schedule 4 table sets four conditions, and a ‘no added sugar’ claim has to satisfy all of them. The food must not be an added sugar. It must not contain an added sugar as an added ingredient, and that extends to the ingredients of a compound ingredient. It must not contain more sugars than 10 g/100 g for solid food or 7.5 g/100 mL for liquid food. And it must not have had its concentration of hexose monosaccharides and disaccharides increased by hydrolysis of carbohydrates during production, unless that concentration sits at or below 1.5%.

The definition of an added sugar is a list, and the list is longer than most people expect. Honey is on it. So are malt and malt extracts, invert sugar, icing sugar, glucose syrup, maltodextrin, starch hydrolysate, anything derived at a sugar refinery, and sugar or sugar syrup derived from plants. Concentrated and deionised fruit and vegetable juices are on it too, except where the food for sale is a prescribed beverage, a fruit juice, juice blend, fruit drink, formulated beverage, brewed soft drink, vegetable juice or water-based beverage.

The same conditions carry into ‘unsweetened’ claims, which require the food to meet the no added sugar conditions and to contain none of the listed polyols or intense sweeteners.

Then, in March 2026, FSANZ abandoned Proposal P1058, the proposal to require added sugars in the NIP. The abandonment report concluded there was no demonstrable public health benefit, that the information carried a risk of misleading or confusing consumers, and that mandating it would impose substantial cost on industry and regulators. The P1062 claim conditions are unaffected and remain in force.

Read those two decisions together and a position emerges. Australia has a legal definition of added sugars that governs a marketing claim, and no added sugars figure anywhere on the panel. Total sugars for information. Defined added sugars for claims. Nothing else.

That is not indecision. That is a regulator concluding that the terminology helps in one place and hurts in another.

The dates you actually need

The transition period runs from 13 December 2023 to 13 December 2027. During that window, a product may be sold if it complies with the Code as it stood before the variation, or the Code as varied, but not a combination of the two.

There is then a post-transition period from 14 December 2027 to 14 December 2029, during which a product packaged and labelled before the end of the transition period may still be sold under either version.

That sounds generous. It is not, if you are printing artwork this year for a product with a two-year shelf life and a claim on the front of pack.

What this means if you’re building a product

Do not reformulate around a scientific debate. Reformulate around the claim conditions, because those are the words that will be enforced.

If you are chasing a ‘no added sugar’ claim, work out which condition is going to catch you, because they fail in different ways. A honey-sweetened product fails at the first hurdle: honey is an added sugar, full stop. So does anything sweetened with apple juice concentrate, unless the product itself is one of the prescribed beverages.

Whole dates, date paste and fruit purée are a different problem. None of them appears on the added sugars list, so they clear the ingredient test cleanly, and then the product runs into the sugar ceiling anyway, because a date-based bar will comfortably exceed 10 g/100 g. Clean ingredient list, failed claim.

The hydrolysis condition is the one almost nobody sees coming. If your process uses enzymes to break down starch and that lifts the sugars in the finished product above 1.5%, the claim is gone even though you added nothing. Plant-based milks are the obvious category here, but any process that converts starch to sugar sits in the same trap.

Check the number and check the process before you print the claim. Not after.

And if the terminology shifts in five years, and it may well, the businesses that survive the change will be the ones whose labels were built on the conditions in the Code rather than on the language in the marketing brief.

We should be leading this conversation

Nutrition professionals need to take control of these conversations as the experts, instead of leaving consumers caught in the middle of a fight between two camps who each believe the other is acting in bad faith.

The paper is a genuine contribution. So is the pushback it will attract. What would be a waste is if the whole thing plays out as a proxy war and the definitions end up settled by whoever shouts longest.

What’s your take?

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