Polyol Labelling for Gelato: The 10 Percent Warning Rule
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Above 10 percent added polyols, an EU label has to carry the sentence about laxative effects. In a milk gelato that line sits at 100 g per 1000 g of mix, and a straight maltitol swap clears it on the first try. Here is where every trigger falls, in grams.
The 10 Percent Line and Where a Real Recipe Crosses It
Quick reference. Annex III of Regulation (EU) No 1169/2011 requires foods containing more than 10 percent added polyols to state "excessive consumption may produce laxative effects". Per 1000 g of mix that is 100 g. Replacing the 135 g of sucrose in a standard milk gelato with maltitol puts you at 135 g, and matching the sweetness puts you at 159 g.
Start from a normal recipe. A milk gelato sits at 16 to 22 percent sugars, so take 19 g per 100 g of mix, of which roughly 5.5 g is lactose that arrives with the milk and about 13.5 g is added sucrose. Per 1000 g of mix that is 135 g of sucrose available to replace.
Swap it gram for gram with maltitol and you are at 135 g of added polyol, which is 13.5 percent, and the warning is mandatory. Worse, maltitol has a sweetening power of 85 against sucrose at 100, so matching the sweetness takes 159 g, or 15.9 percent. The obvious formulation and the good formulation both trip the same rule.
Staying under 100 g means the polyols stop carrying the whole sugar load. The workable structure is a capped polyol dose of about 95 g for bulk and mouthfeel, fibre such as inulin or polydextrose for the solids the sugar used to bring, and a high intensity sweetener such as steviol glycosides for the sweetness the polyols no longer supply. That is a different recipe, not a substitution, and no added sugar gelato works through the texture consequences.
Why Maltitol Wins and Erythritol Cannot Carry the Load
The reason maltitol dominates sugar free gelato is not sweetness, it is freezing point depression. Per 100 g, maltitol contributes 99 of PAC against sucrose at 100, so it is almost neutral: swap it in and the mix freezes at very nearly the same temperature. Maltitol in gelato covers the dose in practice.
Erythritol is the opposite. It contributes 280 of PAC per 100 g. To match the sweetness of 135 g of sucrose you would need about 193 g of erythritol, which brings roughly 540 of PAC into a mix whose whole budget is 220 to 300. The product would not set in a display case at normal serving temperature. Erythritol is a partial ingredient in gelato, never the whole sugar line, which is the practical half of what erythritol and allulose discusses. Sorbitol sits in between at 179 of PAC and 60 of sweetening power, and it carries the same warning. Maltitol versus sorbitol compares the two directly.
| Sweetener | Sweetening power | PAC per 100 g | Energy, Annex XIV |
|---|---|---|---|
| Sucrose | 100 | 100 | 4 kcal/g |
| Maltitol | 85 | 99 | 2.4 kcal/g |
| Sorbitol | 60 | 179 | 2.4 kcal/g |
| Erythritol | 70 | 280 | 0 kcal/g |
The Energy Line You Are Allowed to Claim
Annex XIV of the same regulation fixes the conversion factors, and they are not negotiable: carbohydrate other than polyols at 17 kJ/g or 4 kcal/g, polyols at 10 kJ/g or 2.4 kcal/g, and erythritol alone at 0 kJ/g and 0 kcal/g.
Run the sugar line of the example through it, per 100 g of finished gelato. The 13.5 g of sucrose declares 54 kcal. Replaced by 15.9 g of maltitol it declares 38 kcal, a saving of 16. Replaced by erythritol the same line declares nothing at all. The headline energy reduction on a maltitol product is therefore modest, roughly 16 kcal per 100 g on a gelato that typically declares around 200, and the marketing has to match the arithmetic rather than the intuition.
Which Sugar Claims a Gelato Can Actually Make
The claims live in a different regulation, Regulation (EC) No 1924/2006, and its annex sets the thresholds. Three of them matter here, and a dairy base fails the first one before the recipe even starts.
Sugars free requires no more than 0.5 g of sugars per 100 g. Under Annex I of 1169/2011, sugars means all monosaccharides and disaccharides present in the food but excludes polyols, and lactose is a disaccharide. A milk gelato carries 5 to 6 g of lactose per 100 g, which is ten times the limit, as is gelato lactose free sets out in detail. No dairy gelato can be sold as sugars free, whatever you do with the sucrose. A plant based or water based product with no fruit sugars is the only route to that claim.
Reduced sugars requires a reduction of at least 30 percent against a similar product. From 19 g per 100 g that means landing at 13.3 g or less. Since 5.5 g of lactose is fixed, the added sugar line has to drop from 13.5 g to 7.8 g, a cut of 42 percent on the part you control. The claim is reachable, but the arithmetic is harsher than the headline percentage suggests.
With no added sugars requires that the product contains no added mono or disaccharides and no other food used for its sweetening properties. Polyols are not mono or disaccharides, so a polyol sweetened gelato qualifies, but fruit juice concentrate and honey do not, and where sugars are naturally present the label should also carry the indication that the product contains naturally occurring sugars. Sweeteners for gelato compared covers which ingredients fall on which side of that line.
Two Extra Constraints Worth Knowing Before You Formulate
The first is erythritol specific. In its 2023 re-evaluation of erythritol as a food additive, EFSA set an acceptable daily intake of 0.5 g per kg of body weight per day, derived from the lowest no observed adverse effect level for diarrhoea. That is an unusual basis for an ADI, which normally comes from a chronic toxicity study rather than from an acute effect, and EFSA reported that estimated exposure already exceeds it for children and adolescents at the high end. For a 20 kg child the whole day allowance is 10 g. An 80 g serving of a gelato at 15 percent erythritol delivers 12 g, so a single serving passes it. That is not a labelling rule, but it is the kind of fact a producer should weigh before building a children's product on erythritol.
The second is simpler. Allulose is not authorised in the European Union. It falls under the novel food regime of Regulation (EU) 2015/2283, applications are pending, and an EFSA opinion published in 2025 could not establish its safety on the dossier assessed. Recipes and supplier decks that arrive from the United States frequently assume allulose, and in the EU that formulation cannot be placed on the market at all.
One last thing, and it matters. Everything above is general orientation drawn from the published texts, not legal advice for your product. The final label is the responsibility of the food business operator placing it on the market, the figures depend on your actual recipe and your actual declared values, and national authorities can add requirements. Check your formulation against the current consolidated text and, for a commercial launch, against a labelling specialist. The allergen labelling article covers the adjacent obligations on the same tub.
Related Concepts
- Sweeteners for gelato compared, the full ingredient by ingredient view.
- No added sugar gelato, how the texture changes when the sucrose leaves.
- Maltitol in gelato, the polyol that behaves closest to sucrose.
- Erythritol and allulose, two sweeteners with very different regulatory standing.
- PAC and POD, the two numbers every swap above is measured in.
