Allulose

Almost everything on this site is about an ingredient whose name hides its origin. Allulose is the opposite problem. Its name is honest and its number is not.

It is a monosaccharide. A sugar, in the plain chemical sense, found in small amounts in figs and raisins and made industrially by converting fructose. It tastes like sugar at about seventy percent of the sweetness. The body absorbs it and then largely fails to metabolise it, excreting most of it unchanged, which is why it carries roughly a tenth of the energy.

So it is a sugar that mostly does not behave like one. What happened next is the interesting part.

Why the panel can say zero

In October 2020 FDA announced the availability of a final guidance and, with it, its “intent to exercise enforcement discretion for the exclusion of allulose from the amount of Total Sugars and Added Sugars declared on the Nutrition Facts and Supplement Facts label and use of a general factor of 0.4 calories per gram (kcal/g) for allulose”.

Read that carefully, because it is doing two separate things.

It is not a rule. Enforcement discretion means the regulation still says what it said, and FDA has said it will not act on this particular divergence pending a rulemaking. The Total Sugars line in the labelling regulation did not change. What changed is what FDA will do about it.

It stops at the sugar lines. Allulose still counts in total carbohydrate. So the panel on an allulose product reads as carbohydrate present, sugars zero, and both statements are correct at once.

This is a genuinely defensible decision. Counting a sugar that supplies almost no energy against an added sugars target would mislead in the other direction. But a reader deserves to know that the zero is a considered regulatory judgement rather than an absence.

What the tolerance data says

Sugar alcohols upset stomachs, which is a whole page on this site. Allulose is not a sugar alcohol, and it is absorbed rather than fermented, so it was expected to be gentler.

A 30 day trial in 50 healthy adults tested 24 and 36 grams a day. Gastrointestinal symptoms occurred in 48 percent of participants, described as mild, transient and most frequent in the first three days, with no significant difference between the two doses.

The authors propose a provisional limit of 0.4 grams per kilogram of body weight a day, which they put at “≈24 g/day for a 60 kg adult”, and they say plainly that longer and larger studies are needed to validate it.

Half of participants having something is not nothing. It is also not the same as half being unwell, and the first three days pattern suggests adaptation rather than injury.

The part that matters for a smaller body

That provisional limit is expressed per kilogram of body weight, and that is not a detail.

Twenty four grams is a reasonable adult figure. For a twenty kilogram child the same rule gives eight grams, which is less than one serving of many products built on this sweetener. The tolerance threshold scales with the child and the serving size does not.

Nothing here suggests harm. It suggests that a product engineered to let an adult eat freely is not automatically a product a small person can eat freely, and the label carries no warning to that effect because none is required.

Reading it next to its relatives

Erythritol is the closest comparison and the two are often confused. Erythritol is a sugar alcohol, excreted largely unchanged, and it carries an open cardiovascular question. Allulose is a true sugar, absorbed and not metabolised, and it does not carry that question.

Stevia and monk fruit are hundreds of times sweeter than sugar, so they cannot provide bulk. Allulose can, which is why it appears in baked and frozen products where the others fail. It also browns, which sugar alcohols do not.

In the European Union allulose is not authorised for general food use, so a product you can buy in one market may not exist in another. That is the same pattern set out on Monk fruit.