Cookie with Fiber and Omega-3 Claims

A 2.2 oz, 293 calorie packaged cookie advertises “high fiber” on the package and “excellent source of omega 3” on the Web site. 


This is a big cookie, and for labeling purposes should really be 2 servings rather than one (see 21 CFR Sec. 101.12, Table 2, showing one serving of a cookie to be 30 g), which would more than cut in half the 3 g of fiber stated on the Nutrition Facts label (only available on the Web site). The resulting fiber content is not enough to claim “high fiber.” The omega 3 claim is not allowed because that nutrient does not currently have a daily reference value (DV) established for nutrition labeling (see for a list of nutrients with established DVs). As for the “293” calories, this value is not rounded pursuant to labeling regulations (it should be 300), which is a tip-off that the label was unprofessionally created, and therefore all of the data and claims are suspect. The product is, however, good tasting and a nutritional improvement over other manufactured cookies.

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