DyeConverterTM

Solutions · Ingredient Reformulation

Allulose audit& replacement.

Allulose had a strong run as the sugar that did not count as sugar. A July 2026 federal appeals ruling changed the risk around that claim, so products built on it deserve a fresh look.

Available as an advisory project

What changed in 2026

FDA’s 2020 guidance says the agency intends to exercise enforcement discretion so allulose can be left out of Total Sugars and Added Sugars and counted at 0.4 calories per gram. FDA framed that as pending rulemaking.

On July 27, 2026, the Seventh Circuit held in Franco v. Chobani that allulose is a sugar under 21 CFR 101.9(c)(6)(ii), and it allowed a consumer deception suit over “zero sugar” claims to proceed. FDA’s own brief in that case said total sugars include all monosaccharides, and that its guidance made no statement about nutrient content claims.

This was a pleadings-stage decision, and other defenses remain open on remand. It does not say your label is unlawful. It does mean a sugar free or zero sugar claim on an allulose product deserves review by your counsel now.

Market access

FDA’s inventory shows 12 “no questions” responses on D-psicose notices, the latest on October 7, 2026, with one more pending. Each notice is specific to a notifier’s ingredient and stated uses, so confirm yours is covered.

Outside the US, it is not portable. EFSA concluded in 2025 that the safety of D-allulose could not be established, because the data supplied were incomplete, and that opinion is not a finding of harm. Australia and New Zealand permitted it in 2024. Confirm the UK, Canada, Japan and other markets directly before you plan around them.

How it behaves in the product

It is a capable ingredient with real limits, and each of these changes a formula decision:

  • Sweetness: about 70 percent of sucrose in a 2026 review.
  • Browning: as a reducing sugar it enters Maillard chemistry directly, and studies report heavier browning in bakery.
  • Tolerance: a small trial in young adults proposed a maximum of 0.4 g per kg of body weight in one dose, with severe diarrhea seen in some subjects at 0.5 g per kg.
  • Frozen desserts: as a monosaccharide it should lower freezing point more per gram than sucrose, so test texture in your mix.

Questions R&D teams ask

Can we still say zero sugar on a product with allulose?

That now carries litigation risk. The Seventh Circuit held allulose is a sugar under the federal definition and let a zero sugar deception suit proceed. It was an early-stage ruling, so have your counsel review the claim.

Did FDA reverse its position?

FDA’s brief describes the 2020 guidance as an enforcement position, not an interpretation of the regulation. The guidance itself has not been withdrawn, and we found no rulemaking since it was issued.

Can we sell the same allulose product in Europe?

No. We found no EU authorization, and EFSA’s 2025 opinion said safety could not be established on the data supplied. Australia and New Zealand have permitted it.

Why would a brand replace allulose rather than keep it?

The usual reasons are claim exposure, export plans, heavy browning and tolerance at higher serving levels. Often the right answer is to adjust the dose or the claim rather than remove it, which is what the audit settles.