1. The two claims answer different questions
‘No added sugar’ is a formulation and process question: were sugars or ingredients functioning as sugar substitutes added? ‘Sugar-free’ is a quantity question: is the food's sugar content below the applicable limit?
A product can therefore contain no added sugar yet still contain sugars naturally contributed by durian or other ingredients. Treating the phrases as synonyms misstates the evidence boundary.
2. Thai criteria look beyond a bag of table sugar
Appendix 4 to Notification No. 445 sets conditions for ‘no sugar added’: ingredients containing added sugar must not be used; sugar or sugar-containing ingredients must not be added to act as a substitute; and sugars produced by processing must meet the stated condition.
Review the complete formula tree—base, filling, coating, seasoning, concentrates and supplier formulations—not only whether sucrose appears as a line item.
3. A high-intensity sweetener does not create automatic eligibility
A Thai FDA Food Division FAQ dated 22 April 2024 says a product containing a sweetener in place of sugar may display ‘no added sugar’ if the stipulated conditions are met. That answer is not a blanket clearance for every formula.
The product team must still review the sweetener's identity and function, additive permissions, any related warning or qualifying text, and the real SKU's nutrition label.
4. ‘Sugar-free’ needs quantity evidence
Notification No. 445 sets the sugars-free criterion at no more than 0.5 g per 100 g for solid foods and no more than 0.5 g per 100 ml for liquids, together with the other conditions in the Annex.
Label values need a suitable calculation or analysis representative of the marketed food. Reading a formula and declaring zero, or borrowing a result from a different prototype, does not establish the finished SKU's status.
5. Origin context follows the ingredient; it does not replace the result
Durian source, ripeness and season can affect raw-material characteristics and sweetness, but a province or cultivar name does not state the finished snack's sugar content.
Connect supplier, orchard or collection source, receiving date, ingredient lot, specification and actual formula. This makes variation traceable without turning origin storytelling into a nutrition endorsement.
6. Codex aligns the logic; the destination market decides
Codex CXG 23-1997 likewise separates non-addition-of-sugars conditions from the sugar-free content criterion. A March 2026 Codex Committee on Food Labelling working paper notes that added-sugars labelling rules differ by country or region.
The March 2026 paper is a working document, not a newly adopted worldwide rule. Exporters must check wording, translation, reference units, disclaimers and destination requirements on the actual label-approval date.
7. Seven-layer Sugar Claim Evidence File
This is an evidence-organising framework, not a standard, certification or finding that a product qualifies.
- Product identity: SKU, formula, label version, pack size and market
- Formula map: base, sub-formulas, coating, filling, seasoning and processing aids
- Ingredient evidence: supplier specification, ingredient composition, added-sugar status and lot
- Process evidence: addition points, concentration, hydrolysis, rework and batch records
- Nutrition evidence: sampling plan, method or calculation, unit, result, uncertainty and representativeness
- Claim approval: wording, language, market criterion, disclaimer, nutrition panel, reviewer and date
- Lifecycle control: supplier, formula, process, artwork, production, deviation, change and record retention
8. Editorial and claim boundary
This article is an editorial framework for separating questions and organising evidence. It is not legal advice, a laboratory report or label approval.
Siam Diamond Journal does not claim that Siam Diamond has a no-added-sugar or sugar-free durian snack, analytical results, an approved label or certification from any cited authority.
