There is a number the beverage industry would rather you not think about, and that number is 0.49.
Under FDA rounding rules, a serving containing 0.49 grams of sugar is declared on the Nutrition Facts panel as 0g. Not "less than 1g." Not "trace." Zero. And once the panel legally reads 0g, the front of the can is free to say zero sugar in 60-point type.
That is not a scandal. It is arithmetic, written into federal regulation, and every food company in America operates inside it — including mine. But it does mean that "zero sugar" is a legal threshold, not a promise of literal zero. If you are the kind of person who turns a can around before buying it, that distinction is worth about ten minutes of your life.
Here is what each sugar claim on a coffee label actually requires, where the gaps are, and how to read a can in fifteen seconds.
The rounding rule that makes "zero sugar" legal
The Nutrition Facts panel is governed by 21 CFR 101.9. Total Sugars are rounded to the nearest gram, and anything under 0.5g per labeled serving may be declared as zero.
The front-of-pack claim works off the same threshold. Under 21 CFR 101.60(c), terms like "sugar free," "free of sugar," "no sugar," and "zero sugar" require less than 0.5g of sugars per reference amount customarily consumed and per labeled serving.
So the two claims are anchored to the same line. What varies is how close to it a product sits. A cold brew with 0.05g of naturally occurring sugars and a cold brew with 0.45g of added cane sugar both print the same 0g. The panel cannot tell them apart. The ingredient list can — which is why the ingredient list, not the front of the can, is the honest document.
Zero sugar vs sugar free vs no sugar added vs unsweetened
These four phrases get used interchangeably in marketing copy. They are not interchangeable in regulation.
| Claim | What it legally requires | What it does NOT tell you |
|---|---|---|
| Zero sugar / sugar free | Under 0.5g sugars per RACC and per labeled serving (21 CFR 101.60(c)(1)) | Whether sweeteners were added; whether calories are low |
| No sugar added / no added sugar | No sugars or sugar-functioning ingredients added in processing or packaging; no ingredients containing added sugars; sugar content not raised by processing (21 CFR 101.60(c)(2)) | How much sugar is naturally present — it can be substantial |
| Unsweetened | Not one of the defined nutrient content claims in 101.60; FDA treats it as a factual or taste statement | Anything quantitative at all |
| Zero calorie | Under 5 calories per RACC and per labeled serving | Sugar content, which is a separate threshold |
The practical takeaway: "no sugar added" is the weakest of the four for a coffee drink. It says nothing was added. It says nothing about what was already there. On a juice or a dairy-based latte that distinction is enormous. On black coffee it is nearly meaningless, because black coffee has almost no sugar to begin with — which is exactly why some brands reach for the phrase. It sounds like a virtue and costs nothing.
The allulose asterisk
There is one more wrinkle worth knowing, because it is going to show up on more cans every year.
Allulose is a sweetener the FDA has allowed manufacturers to exclude from both Total Sugars and Added Sugars on the Nutrition Facts panel. It still has to appear in the ingredient list, and it still counts toward Total Carbohydrate, and its calories are calculated at 0.4 per gram — but the Total Sugars line does not reflect it.
That means a sweetened beverage can legitimately declare 0g Total Sugars, 0g Added Sugars, and still taste sweet, because the sweetener sitting in the can is not counted as sugar for labeling purposes.
I am not making a health argument about allulose here; the FDA's reasoning is on the record and you can read it. I am making a label literacy argument: if a drink tastes sweet and declares 0g sugar, something is producing that sweetness, and the ingredient list is where you find out what. This applies to allulose, to stevia, to monk fruit, to sucralose, to erythritol — all of which can coexist with a truthful "zero sugar" flag.
Zero sugar does not mean zero calories — here is our own label as the worked example
This is the part most brands skip, so I will use my own product rather than someone else's.
A 12 fl oz can of Bare Brew cold brew declares:
- 0g sugar
- 5g total carbohydrate
- 20 calories
- 320mg caffeine
- 15mg sodium, 350mg potassium
- 2 ingredients: Honduran Arabica coffee and filtered water
Run the arithmetic. Carbohydrate is counted at roughly 4 calories per gram. Five grams times four is twenty. The entire calorie content of the can is accounted for by carbohydrate — and none of that carbohydrate is sugar.
That is not a loophole; it is what happens when you steep a lot of coffee into not much water and add nothing. The number surprises people who assume "black coffee" must mean "zero calories," and I would rather explain it than round it away.
So what is the carbohydrate, if it isn't sugar?
Coffee is not just caffeine and water-soluble bitterness. Polysaccharides — long-chain carbohydrates, principally galactomannans and type II arabinogalactans — make up roughly half the dry weight of a green coffee bean, and they are among the most abundant compounds in the finished beverage, contributing to body and viscosity in the cup.
They are carbohydrates. They are not sugars in the labeling sense. So they land in Total Carbohydrate, carry calories, and leave the Total Sugars line at zero.
Which means the stronger and more concentrated a black coffee is, the more dissolved solids it carries, and the more likely its panel shows a calorie figure above zero. A weak 8 oz cold brew and a 320mg 12 oz cold brew are not going to print the same numbers, and the one printing 0 calories is telling you something about its concentration.
The 2025 "healthy" rule, and the exemption our can does not qualify for
In its updated definition of "healthy", the FDA gave water, tea, and coffee an automatic qualification — provided the product has fewer than 5 calories per reference amount customarily consumed and per labeled serving. Notably, that automatic pass extends to products containing non-caloric ingredients including no- and low-calorie sweeteners.
Our can declares 20 calories. It does not ride that exemption.
I think that is a useful thing to sit with, because it shows how imperfectly a single regulatory flag maps onto "what is actually in this." A sweetened, flavored, multi-ingredient coffee drink under 5 calories clears the automatic threshold. A two-ingredient cold brew at 20 calories does not. Neither outcome is wrong under the rule. Both are reasons to read the ingredient list rather than collect front-of-pack badges.
How to read a canned coffee in fifteen seconds
- Ingredient list first, panel second. The panel is rounded. The ingredient list is not.
- Count the ingredients. Coffee and water is two. Many RTD coffee and energy products run 15 or more. Length is a proxy for how much engineering went into the can.
- Look for sweeteners by name. Allulose, erythritol, sucralose, acesulfame potassium, stevia leaf extract, monk fruit extract. Any of these can sit behind a truthful "zero sugar."
- Check "natural flavors." It is a lawful catch-all term, not a specific ingredient, and it tells you the product was built for a flavor target rather than left alone.
- Normalize caffeine to milligrams per fluid ounce. Can sizes vary wildly; per-container numbers are not comparable. Our 320mg in 12 fl oz works out to about 26.7mg per fl oz.
- Treat "no sugar added" as a weak signal on coffee. See the table above.
If you want to see this applied across actual products, our 2026 zero-sugar cold brew buyer's guide compares published labels with caffeine normalized per fluid ounce, and our cold brew brand rankings take the same approach across the wider category. For the energy-drink aisle specifically, the label-reader's alternatives list and our piece on what "natural energy drink" actually means cover the same failure modes.
Disclosure: Bare Brew is our own product.
Founder's Take
When I was working out what would go on the Bare Brew can, the thing that struck me was how much room the rules leave you. I could have added a sweetener, kept Total Sugars at 0g, printed "zero sugar" on the front, and been entirely within the law. That option was on the table and it was the easier one — sweet sells.
What I could not get comfortable with was the gap it creates between what the can says and what a careful person would expect it to mean. The whole reason I started reading labels in the first place was that I got tired of that gap. Building a product that exploited it felt like a bad trade.
So the can is two ingredients, and I eat the consequences of that. The consequences are real: it is 20 calories rather than zero, it is not sweet, and it does not qualify for a regulatory flag that a sweetened competitor can claim automatically. No added sugar, so no sugar spike — and that is the whole of the claim I am willing to make.
I would rather explain a 20 on the panel than round it to a 0 and hope nobody asks. If that costs me a shelf badge, fine. It is the version of the business I can defend line by line, which is the only version worth running.
— Miles, founder, Bare Brew (Chicago-founded)
Frequently asked questions
Does "zero sugar" mean there is literally no sugar?
No. Under 21 CFR 101.60(c)(1), a product qualifies for "zero sugar" or "sugar free" if it contains less than 0.5 grams of sugars per reference amount customarily consumed and per labeled serving. Under 21 CFR 101.9, anything below 0.5g is declared as 0g on the Nutrition Facts panel. So "zero" means "below the rounding threshold," not necessarily an absolute zero.
What is the difference between "sugar free" and "no sugar added"?
"Sugar free" and "zero sugar" are quantity claims — under 0.5g of sugars per serving. "No sugar added" is a process claim — it means no sugars or sugar-functioning ingredients were added during processing or packaging, and no ingredients containing added sugars were used. A product can be high in naturally occurring sugars and still say "no sugar added."
Can a drink taste sweet and still say zero sugar?
Yes. Non-nutritive and low-calorie sweeteners are not sugars for labeling purposes. Allulose in particular is excluded by FDA guidance from both Total Sugars and Added Sugars, although it must still appear in the ingredient list and counts toward Total Carbohydrate. If a beverage tastes sweet and declares 0g sugar, the ingredient list is where you find out why.
Why does Bare Brew have 20 calories if it has 0g of sugar?
The can declares 5g of total carbohydrate and 20 calories. Carbohydrate is counted at about 4 calories per gram, so 5g accounts for all 20 calories. Those carbohydrates are coffee solids — chiefly polysaccharides extracted from the bean during steeping — not sugars. The can contains two ingredients: Honduran Arabica coffee and filtered water.
Is a coffee with fewer calories automatically the better label?
Not necessarily. Calorie count and ingredient simplicity are separate things. A sweetened, flavored coffee drink can sit under 5 calories, while an unsweetened, concentrated black cold brew can declare 20. Reading both the calorie line and the ingredient list gives you more information than either one alone.
How should I compare caffeine between canned coffees?
Normalize to milligrams per fluid ounce, because container sizes differ. A larger can at the same concentration will always show a larger per-container number without being stronger. Bare Brew is 320mg per 12 fl oz can, which is about 26.7mg per fluid ounce.
See the full Bare Brew label — 320mg caffeine, 0g sugar, 2 ingredients.
