The Dietary Fiber line this panel does not print

Exhibit 01

An absence that asserts something

The most useful thing on this panel is a line that is not on it. Learning to read a missing line is the single most transferable skill a Supplement Facts panel teaches, and this one teaches it cleanly.

Here is the carbohydrate block as printed: Total Carbohydrate 2 g at 1% of the Daily Value, then Total Sugars 1 g indented under it, then Includes Less Than 1g Added Sugars at 0%. And then the next line of the panel is the Bacillus coagulans line. There is no Dietary Fiber row between them. Not a zero, not a dash, not a footnote. The row is absent.

A reader is entitled to treat that as information, because the regulation makes it information. 21 CFR 101.9(c)(6)(i) requires dietary fibre to be declared “except that if a serving contains less than 1 gram, declaration of dietary fiber is not required” ^{21 CFR 101.9}

Notice how narrow that is. The absence does not say there is no fibre, and it does not say how much there is. The reference figure a printed line would have carried a percentage against is 28 g, so even a full gram would have been a small percentage: the line came off because of a threshold, not because the quantity was uninteresting.

Exhibit 02

The two calorie factors, and the one the regulation leaves out

Calories on a label are not measured in a bomb calorimeter and then printed. They are calculated with factors the regulation specifies, and for carbohydrate there is more than one factor.

21 CFR 101.9(c)(1)(i)(C) is the relevant text. Digestible carbohydrate is counted at 4 calories per gram, the general factor for carbohydrate. For the non-digestible part the regulation is explicit and narrower than most readers expect: “A general factor of 2 calories per gram for soluble non-digestible carbohydrates shall be used.” ^{21 CFR 101.9}

A general factor of 2 calories per gram for soluble non-digestible carbohydrates shall be used.

Read what that sentence covers. It names soluble non-digestible carbohydrate and gives it 2 calories per gram. It sets no express factor for the insoluble part, which is why this post carries insoluble fibre as its own column below and treats it as contributing nothing. That last step is a reading of the quoted text rather than a figure the regulation states, and it is flagged here rather than smuggled in, because the whole argument turns on it.

So carbohydrate on a panel can be worth 4 calories a gram, 2 calories a gram, or nothing a gram, depending on which kind it is. The declared 2 g is a single number covering all three possibilities, and the calorie line is the only clue the panel gives as to how it splits.

Exhibit 03

Every way the declared 2 g can split

Four splits, the factors applied to each, and the calorie figure each one would have forced the panel to print. The arithmetic is shown so it can be checked rather than believed.

Work down the table. With no fibre at all, 2 g of digestible carbohydrate is 8 calories, which is double what the panel declares. With a gram of soluble fibre, the sum is 6, which is a value the regulation makes available and is not the one printed. With half a gram of each kind, the sum is 5, which is also available and also not printed. With a full gram of insoluble non-digestible carbohydrate, the sum is 4, and that is the figure on the bottle.

So exactly one of the four splits reproduces the printed calorie figure, and it is the one that puts a full gram of non-digestible carbohydrate in a gummy whose panel carries no Dietary Fiber line.

The other rows say something about the shape of the problem. Every split that stays under a gram of fibre produces 5 calories or more, and the printed figure is lower than any of them. The only way down to it is through the one door the missing line closes.

Exhibit 04

Both sides of the same threshold

One number does two jobs on this panel, and they pull against each other. A gram of non-digestible carbohydrate is what the calorie figure needs, and a gram is exactly what the missing line forbids.

That is the finding, and it is symmetrical. It does not matter which side of the threshold the real serving sits on: one of the two printed statements fails on either side. Under a gram, the calorie line cannot be reached. At a gram or more, the fibre line cannot be left off.

At 4 calories per gram for digestible carbohydrate, 2 g is 8 calories. Reaching 4 requires about a gram of non-digestible carbohydrate - which would have required a Dietary Fiber line the panel does not print.

This post does not resolve which statement is wrong, because nothing published settles it and guessing would be worse than leaving it open. What it does is name the one fact that makes the question askable at all: the first ingredient in the 430 mg blend is Chicory Root Inulin, which is a non-digestible carbohydrate, and the first of the Other Ingredients is Glucose Syrup, which is not. Nothing on the panel says how much of either is in a gummy.

Exhibit 05

What this does not mean

An argument of this kind attracts conclusions it does not support, so here are the ones it does not support, before anybody else supplies them.

• It does not mean the gummy contains a gram of fibre. The panel does not say so and neither does this post.
• It does not mean the gummy contains no fibre. The absent line rules out a gram and rules out nothing else.
• It is not a safety finding. A gram of fibre either way is a gram of fibre, and nobody is harmed by the difference.
• It is not a statement about the inulin. Chicory root inulin is first in the declared order, so it is capped at 430 mg, the whole blend restated, which rules nothing out. Every figure of that kind is a ceiling: the most an ingredient could weigh, never the amount in the gummy, and the real weight could be very much smaller.

A Dietary Fiber line is on the list of things this label does not publish, and that is where it stays: No Dietary Fiber is declared on this panel at all. The disclaimer publishes the whole list, with the reason each item is on it.

There is one comparison worth making and it needs its own caution. FDA’s 2018 review of non-digestible carbohydrates puts the studied intake for inulin-type fructans at “3 to 40 g/day” ^FDA a day. The whole 430 mg blend, all nine botanicals together, is 14 per cent of the lowest figure in that range. Read that comparison carefully. The effect FDA recognised in that review is on bone mineral density and the absorption of calcium. It is not a gut finding, and no page on this site treats it as one.

FDA also publishes a plain-language page on which carbohydrates count as dietary fibre. ^FDA The label page works the same arithmetic again with every line annotated, and the blend guide is where the blend ceilings come from.