The short answer
In the EU, nutrition claims on gummies are governed by Regulation (EC) No 1924/2006. “Sugars-free” needs no more than 0.5 g sugars per 100 g, “low sugar” no more than 5 g per 100 g, “source of fibre” at least 3 g fibre per 100 g and “high fibre” at least 6 g per 100 g. The claim always depends on the analysed finished product — not on the base formulation.
The legal framework
Nutrition and health claims on foods sold in the EU are harmonised by Regulation (EC) No 1924/2006. Only the nutrition claims listed in its Annex may be used, and only when the product meets the conditions attached to each claim. Claims that mean the same thing to consumers — for example “zero sugar” for “sugars-free” — must meet the same conditions.
Labelling in general, including the nutrition declaration and mandatory statements, is governed by Regulation (EU) No 1169/2011. Together, these two regulations decide what a sugar-free or fibre gummy can say on its pack.
Sugar claims and their thresholds
“Sugars” in EU labelling means all mono- and disaccharides — including glucose, fructose, sucrose and lactose — regardless of source. Polyols and most fibres are not counted as sugars.
- Sugars-free: no more than 0.5 g sugars per 100 g or 100 ml.
- Low sugar: no more than 5 g sugars per 100 g for solids.
- Reduced sugar: at least 30 % less sugar than a comparable product, with the same or less energy.
- No added sugars: no added mono- or disaccharides or any other food used for its sweetening properties. Where sugars occur naturally, the label should also state “contains naturally occurring sugars”.
Fibre claims and their thresholds
Fibre claims are based on the fibre content of the finished product, analysed using recognised methods.
- Source of fibre: at least 3 g fibre per 100 g or at least 1.5 g fibre per 100 kcal.
- High fibre: at least 6 g fibre per 100 g or at least 3 g fibre per 100 kcal.
Why pectin alone rarely makes a fibre gummy
Pectin is a soluble dietary fibre, but a typical pectin gummy contains only a few percent pectin — enough to gel, not enough to reach 3 g or 6 g per 100 g. A fibre-claim gummy therefore needs a dedicated formulation with added, named fibres. Our Fiber system, for example, is built with FOS, tapioca fiber and inulin in a distinct pectin recipe.
Polyols and the laxative-effect statement
Many sugar-free gummies on the market use polyols (sugar alcohols) such as maltitol, sorbitol or isomalt. If a food contains more than 10 % added polyols, Regulation 1169/2011 requires the statement “excessive consumption may produce laxative effects”. The Zero and Fiber systems have no sugar alcohols in the base, but check every other ingredient in your recipe before finalising the label.
Health claims are a separate track
Statements about what a food does for the body — such as fibre supporting digestion — are health claims. They are only allowed when authorised in the EU Register of nutrition and health claims, used with the authorised wording and conditions of use, and accompanied by the mandatory information. A nutrition claim such as “high fibre” does not automatically permit a health claim.
Base vs finished product
A base formulation never automatically qualifies a pack claim. Coatings, flavours, colours, inclusions and the final water content all change the numbers. For example, a sanded-sugar finish adds sugars that may push a Zero gummy above 0.5 g per 100 g — which is why wax is recommended for Zero and Fiber.
Always analyse the finished product, keep the results on file, and confirm wording with your labelling or regulatory team for each market.
National requirements: Denmark and Germany
The EU thresholds are the same in every member state, but each market adds its own requirements: the label must be in the official language(s), national authorities publish guidance and enforcement practice, and some markets have additional rules for food supplements. In Denmark, the Danish Veterinary and Food Administration (Fødevarestyrelsen) oversees labelling; in Germany, enforcement is handled by the federal states’ food control authorities.
A practical claims checklist
- Choose the system that matches your claim from the start: Zero for sugar-free development, Fiber for fibre claims.
- Pick a finish that does not add sugars when you plan a sugar claim.
- Analyse the finished gummy for sugars, fibre, polyols and energy.
- Check the exact claim wording against the Annex of Regulation 1924/2006.
- Add mandatory statements where needed, such as the polyol statement.
- Translate and review the label for every market.
Sugar-free and fibre wording applies to the finished product, not automatically to the base. Verify each formulation and market with your labelling team. Sugars-free claims require the finished product to meet EU Regulation 1924/2006 (≤ 0.5 g sugars per 100 g or 100 ml).
Questions buyers ask
Does Zero automatically allow a sugar-free claim?
No. Zero is designed for sugar-free development, but the finished product must meet the 0.5 g per 100 g threshold after analysis.
Can I say “zero sugar” instead of “sugars-free”?
Claims with the same meaning for consumers must meet the same conditions. Check wording with your labelling team.
Does pectin count as fibre on the label?
Pectin is a dietary fibre and counts toward the fibre content, but the amount in a standard gummy is usually too low for a fibre claim.
Do national rules also apply?
Yes. Language requirements and national guidance apply in each market, such as Denmark and Germany.
Is this legal advice?
No. This guide is general information for business buyers. Confirm claims and labelling for each finished product and market.
General information for business buyers, not legal or regulatory advice. Confirm claims and labelling for each finished product and market.