Why fibre isn't a carbohydrate on UK food labels: Regulation 1169/2011 explained

A technical manager building a spec sheet for a product launching in both the UK and the US recently found the two nutrition panels didn't match. Same recipe, same batch, same lab. But the UK carbohydrate figure came in lower than the US Total Carbohydrate figure on an identical product. Nobody had made an error. The two countries define carbohydrate differently, and fibre is the reason why.

This trips up more teams than you'd expect, especially now. Fibre-forward products are one of 2026's biggest NPD briefs, and NPM 2018 has just doubled the maximum points available for fibre, from 5 to 10. More products are being built around a fibre claim than at any point in the last decade. Getting the label mechanics right matters more than it used to.

What Regulation 1169/2011 actually says

Regulation (EU) No 1169/2011, retained in UK law post-Brexit as UK FIC, defines available carbohydrate and fibre as two separate things in Annex I.

"Carbohydrate" means any carbohydrate metabolised by humans, and includes polyols. That's it. It's a definition built around what the body can break down and use for energy.

"Fibre" is defined separately: carbohydrate polymers with three or more monomeric units, which are neither digested nor absorbed in the human small intestine. The definition is doing real work here. Fibre is still, chemically, a carbohydrate. But because the body doesn't process it the way it processes sugars and starches, the regulation treats it as its own category rather than folding it into the carbohydrate figure.

That's why your nutrition declaration shows carbohydrate and fibre as two separate rows, not one nested inside the other.

What has to appear on the label, and what's optional

Article 30 sets out the mandatory nutrition declaration: energy, fat, saturates, carbohydrate, sugars, protein, and salt. Fibre isn't on that list. It's one of the supplementary items, alongside polyols, starch, and specific vitamins and minerals, and only becomes mandatory if you're making a claim about it.

In practice, most brands declare fibre anyway. If your NPD brief includes a "source of fibre" or "high fibre" claim, or you're feeding data into NPM scoring, you'll need the figure regardless of whether the regulation strictly requires it. But it's worth knowing the baseline: carbohydrate is mandatory, fibre is conditional.

Why the UK figure won't match a US spec sheet

This is where the cross-market confusion comes from. The FDA's Nutrition Facts label builds Total Carbohydrate "by difference": it's calculated as everything left over once protein, fat, water, and ash are subtracted, and dietary fibre sits inside that total as a sub-line, not outside it.

Regulation 1169/2011 takes the opposite approach. Carbohydrate is defined by what's metabolised, fibre is defined by what isn't, and the two never overlap on the label. For a product with 8g of fibre per 100g, the US panel folds that 8g into Total Carbohydrate. The UK panel doesn't. Copy a US spec sheet across to a UK launch without adjusting for this, and your carbohydrate figure will be wrong, sometimes by a meaningful margin on high-fibre products.

If you're managing dual-market NFPs, this is the first thing to check, not the last.

There's a second reason the numbers diverge, and it matters if you're pulling raw values from CoFID rather than a platform that's already converted them. CoFID, the UK's own composition database, has historically reported carbohydrate as monosaccharide equivalents: starch is recorded including the water of hydration it would release on hydrolysis, and disaccharide sugars are recorded as the mass of monosaccharide they'd yield. That convention runs roughly 9% higher than the by-weight figure Regulation 1169/2011 actually requires. Use a raw CoFID carbohydrate value without converting it, and you're stacking that inflation on top of the fibre difference.

The energy maths that catches people out

Fibre being excluded from the carbohydrate line doesn't mean it's excluded from the energy value. It still contributes calories, just at a different rate, using the conversion factors in Annex XIV:

• Carbohydrate (except polyols): 17 kJ/g, 4 kcal/g
• Fibre: 8 kJ/g, 2 kcal/g
• Polyols: 10 kJ/g, 2.4 kcal/g

So a product with 10g of carbohydrate and 5g of fibre per 100g contributes 170 kJ from the carbohydrate and 40 kJ from the fibre to the total energy declaration, even though only the 10g shows up on the carbohydrate line. It's easy to build a spec sheet that gets the macro rows right but under- or overstates total energy because the fibre contribution got missed in the calculation, or double-counted alongside the carbohydrate figure.

This is also why you'll sometimes see two different UK energy values for what looks like the same product. Some older UK sources, including legacy McCance & Widdowson data, use 3.75 kcal/g for carbohydrate rather than the 4 kcal/g Annex XIV requires on the label. The lower figure was compensating for the same monosaccharide-equivalent inflation described above: since the mono-equivalent carbohydrate value ran about 9% high, a lower energy factor brought the calculated energy back in line. If your spec sheet or a supplier's data still uses 3.75, it's a legacy of that convention, not a different legal requirement.

What this means for a food team

If you're building a fibre-forward product, three things are worth locking down before you finalise a spec sheet.

Get your finished-product fibre figure from an actual test, not the raw ingredient's declared value. Processing, heat, and pH can all shift the fibre content between ingredient and finished product, the same issue we've flagged before when it comes to hitting a "source of fibre" claim in beverages.

Recalculate energy for every market you sell into. The fibre conversion factor doesn't change between the UK and EU, but if you're also selling into the US, don't assume one number travels. The FDA doesn't use a flat factor for fibre. It assigns each recognised fibre its own calorie value (0 kcal/g for most insoluble fibres, 1 kcal/g for polydextrose, around 2 kcal/g for soluble corn fibre), so the US energy value for a given fibre can differ from both the UK figure and from other fibres in the same product.

Check which analytical method your fibre figure is based on. Regulation 1169/2011 doesn't specify a method, but NPM 2018 has moved to AOAC fibre specifically, replacing the older NSP measure. If your supplier's spec sheet still quotes NSP, your NPM score and your label declaration may not be pulling from the same number.

Get this right at spec stage, and the label writes itself. Get it wrong, and you're reworking nutrition panels after the NPM score has already shaped your reformulation targets.

Frequently asked questions

Is fibre a type of carbohydrate?

Chemically, yes. But under Regulation 1169/2011, fibre and carbohydrate are declared as separate nutrients on a UK or EU nutrition label. Carbohydrate is defined as what the body metabolises; fibre is defined as carbohydrate polymers the body doesn't digest or absorb in the small intestine.

Why does the UK carbohydrate figure differ from the US Total Carbohydrate figure on the same product?

The FDA calculates Total Carbohydrate by difference and includes dietary fibre within that total. Regulation 1169/2011 excludes fibre from the carbohydrate figure entirely and declares it as a separate line. The two figures will differ on any product with meaningful fibre content.

Do I have to declare fibre on a UK nutrition label?

Not always. Fibre is a supplementary, not mandatory, declaration under Article 30, unless you're making a nutrition or health claim about it. Most fibre-forward products declare it regardless, since the claim is usually the point of the product.

What's the energy value of fibre per gram?

8 kJ/g (2 kcal/g), under Annex XIV of Regulation 1169/2011. This is separate from the conversion factor for carbohydrate (17 kJ/g, 4 kcal/g) and still needs to be included in the total energy calculation.

Does Regulation 1169/2011 still apply in the UK after Brexit?

Yes. It was retained in UK law as UK FIC (Food Information to Consumers) and continues to apply to labelling across England, Wales, Scotland, and Northern Ireland.

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