healthBS: How to make a
Snickers Bar Fat-Free…


…and how U.S. labeling laws are flawed.

Can there really be a Snickers® bar that is fat-free?

Legally, yes… Technically, no.

Confused? So was I!

Nutrition labeling is a cat and mouse game between manufacturers and federal regulators. With the right legal team and a few snazzy designers, a company can present a fat-filled, heart-attack-inducing concoction as a fat-free health food! Here’s why:

The terms ‘‘fat free,’’ ‘‘no fat,’’ ‘‘zero fat,’’ ‘‘without fat,’’ and ‘‘negligible source of fat,’’ can be used on the label or in labeling of foods, provided that:

1. The food contains less than 0.5gram (g) of fat per labeled serving…


2. The food contains no ingredient that is a fat unless the listing of that ingredient is followed by an asterisk which states, ‘‘adds a trivial amount of fat.”

Enough legalese for you?


Any food that contains less than ½ gram of fat PER SERVING can be labeled as having zero grams of fat in its nutrition facts and be marketed as fat-free! So now, ½ = 0! Where did the FDA study math?!

In the simplest definition, if a serving size of food is small enough so that it only contains ½ gram of fat in that tiny serving, we can say it has no fat and it is fat free! There’s only one very minor, but confusing exception.

Since fat-free foods can contain fat, whichever ingredient in the food that contains the fat have an asterisk next to it. Confused? Let’s use a real-life example to explain.

Go into your pantry and pull out your non-stick cooking spray. First, note the serving size – I bet it’s less than 1 second! It’s typically ¼ or 1/3 of a second spray. Also note, it’s “fat-free” and probably says that on the label somewhere other than just the nutrition facts. Glance down at the ingredients. Find whatever oil your spray contains (e.g. soybean oil, cottonseed oil, canola oil). Then find the little asterisk and note what it says below the ingredients: “adds a trivial amount of fat.” Trivial to whom?!

So in a cooking spray that is basically just vegetable oil sprayed out of a can, since the serving size is so minuscule, the manufacturer can legally label it fat-free, even when the 1st and largest ingredient in the food contains a ton of fat!

Before we go further, it is worth mentioning that there are no fewer than 10 pages of legalese explaining the details of how large or small a serving size can be. After reading through all of them, it seems like there is a justification for literally any size you wish to create. You have to love loopholes!

Now that we’ve climbed that hurdle, let me elaborate on my example from the headline of the article. My favorite candy bar is a Snickers® which contains 13.5 grams of fat. In reality, its serving size is 1 bar.

Time to change that! In order to make it fat-free, we’re going to change the serving size to 1/27th of the bar. Now, my serving will be an astounding 10 calories, with no fat whatsoever! Magic, I know. We’re not done though, we need to doctor our label a little bit further.

Move on to the ingredients list of the Snickers® bar so that we can make sure we follow guideline #2 as outlined above. In order to create a “fat-free” Snickers® bar, we would add an asterisk to the following ingredients: cocoa butter, milkfat, peanuts, butter, partially hydrogenated soybean oil. Once our asterisks are added, we’ll add a very tiny disclaimer that defines the asterisk:

*Adds a trivial amount of fat.

Voila! Our Snickers® bar is now fat-free and legal!

I mean yeah, the serving size is small, so I’ll just lie to myself and eat 27 of these “fat-free” bites… Good thing I have no idea that I actually just ingested an outrageous 13.5 grams after 27 servings…

Sound absurd? It is, I know.

My analysis and examples are all based on real law and facts taken directly from Chapter 21 of the Federal Code of Regulations, section 101.62. If you’d like to beat your head against a wall and try to dive into the regulations on your own, download it here.

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Brian Staffa

Tired of the misinformation within the health & nutrition industry, I write to deliver clear, practical, science-based information so that everyone can improve their health & quality of life.

Health BS