Contains Nonbinding Recommendations 
 
Converting Units of Measure for Folate, 
Niacin, and Vitamins A, D, and E on the 
Nutrition and Supplement Facts Labels:  
Guidance for Industry 
 
 
Additional copies are available from: 
Office of Nutrition and Food Labeling 
Division of Nutrition Programs Staff, HFS-830 
Center for Food Safety and Applied Nutrition 
Food and Drug Administration 
5001 Campus Drive 
College Park, MD  20740 
(Tel) 240-402-1450 
https://www.fda.gov/FoodGuidances 
 
 
You may submit electronic or written comments regarding this guidance at any time. Submit 
electronic comments to https://www.regulations.gov. Submit written comments to the Dockets 
Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, rm. 1061, 
Rockville, MD 20852. All comments should be identified with docket number FDA-2016-D-
4484 and with the title of the guidance document. 
 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Food Safety and Applied Nutrition 
 
August 2019 
 
 
   
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Table of Contents 
 
I.  Introduction 
II.  Background 
III. Conversion Factors 
A. Folate 
B. Niacin 
C. Vitamin A 
D. Vitamin D 
E. Vitamin E 
IV.  Paperwork Reduction Act of 1995 
V.  References 
 
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  Contains Nonbinding Recommendations 
 
Converting Units of Measure for Folate, 
Niacin, and Vitamins A, D, and E on the 
Nutrition and Supplement Facts Labels: 
1
Guidance for Industry  
 
This guidance represents the current thinking of the Food and Drug Administration (FDA or we) 
on this topic. It does not establish any rights for any person and is not binding on FDA or the 
public. You can use an alternative approach if it satisfies the requirements of the applicable 
statutes and regulations. To discuss an alternative approach, contact the FDA staff responsible 
for this guidance as listed on the title page. 
I.  Introduction 
This guidance document provides step-by-step instructions to manufacturers of retail food 
products marketed in the United States on how they may convert the previous units of measure 
for certain nutrients to the new units in the updated Nutrition Facts label (81 FR 33742 at 33906-
33916 and  101.9 (21 CFR 101.9)). This guidance document also provides conversion factors 
that can be used for each of these nutrients and example2 calculations for converting to the new 
units of measure for conventional foods and dietary supplements. Lastly, this guidance document 
provides information that can help manufacturers understand and comply with relevant labeling 
requirements.  
 
FDAs guidance documents, including this guidance, do not establish legally enforceable 
responsibilities. Instead, guidances describe our current thinking on a topic and should be viewed 
only as recommendations, unless specific regulatory or statutory requirements are cited. The use 
of the word should in our guidance documents means that something is suggested or 
recommended, but not required. 
   
                                                           
1 This guidance has been prepared by the Nutrition Programs Staff in the Office of Nutrition and Food Labeling, 
Center for Food Safety and Applied Nutrition at the U.S. Food and Drug Administration. 
2 In the examples provided for conventional foods, the quantity of a nutrient is expressed per serving size, which, in 
this guidance, refers to the serving size declaration on the Nutrition Facts label based on the reference amount 
customarily consumed per eating occasion (RACC) for a specific food category ( 101.12, Tables 1-2) and 
applicable requirements set forth in  101.9(b). For dietary supplements, the nutrient amount is expressed per 
serving size. 
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II.  Background 
 
In 2016, FDA amended the regulations for the nutrition labeling of conventional foods ( 101.9) 
and dietary supplements ( 101.36) to include updated Daily Values (DV), as Reference Daily 
Intakes (RDIs), for folate, niacin, vitamin A, vitamin D, and vitamin E. These RDIs are based on 
the Dietary Reference Intakes (DRIs), specifically Recommended Dietary Allowances (RDAs) 
published by the National Academy of Medicine (NAM, formerly known as the Institute of 
Medicine (IOM)). Except for niacin, which had its unit of measure established in the 1989 RDA 
as Niacin Equivalent, the other four nutrients have new units of measure associated with the 
updated RDAs established by the NAM. While the unit of measurement for the RDI for niacin is 
listed as Niacin Equivalents (i.e., mg NE) in  101.9(c)(8)(iv), only the amount mg will 
continue to be declared in labeling. The units of measure for these nutrients in the Nutrition Facts 
label, described in  101.9(c)(8)(iv), also pertain to the Supplement Facts label 
( 101.36(b)(2)(ii)(B)). Table 1 shows the old (1993) and the current (2016) RDIs established 
for these five nutrients: 
 
Table 1: RDIs for the Five Nutrients  
Nutrient  1993 RDI   2016 RDI1 
Folate  400 micrograms (mcg)  400 micrograms DFE2 (mcg DFE3)  
Niacin  20 milligrams (mg)  16 milligrams NE4 (mg) 
Vitamin A  5,000 International Units (IU)  900 micrograms RAE5 (mcg) 
Vitamin D  400 International Units (IU)  20 micrograms (mcg) 
Vitamin E  30 International Units (IU)  15 milligrams -Tocopherol6 (mg) 
1 These RDIs are based on RDAs for adults and children  4 years of age (these RDIs were based on the 
highest RDA for the adult male and/or adult female). 
2 DFE = Dietary Folate Equivalents. Folate and Folic Acid must be used for purposes of declaration 
in the labeling of conventional foods and dietary supplements. The declaration for folate must be in mcg 
DFE (when expressed as a quantitative amount by weight in a conventional food or dietary supplement), 
and percent DV based on folate in mcg DFE. Folate may be expressed as a percent DV in conventional 
foods. When folic acid is added or when a claim is made about the nutrient, folic acid must be declared in 
parentheses, as mcg of folic acid (see  101.9(c)(8)(iv) (footnote 6)). 
3 For label declarations, except for folate, which must be declared in mcg DFE, the name of each nutrient, 
as specified in  101.9(c)(8)(iv), shall be given in a column and followed immediately by the quantitative 
amount by weight for that nutrient appended with a mg for milligrams, or mcg for micrograms as 
shown in  101.9(d)(7)(i) and  101.9(d)(12). 
4 NE = Niacin Equivalents, 1 mg NE = 1 mg niacin = 60 mg tryptophan (see  101.9(c)(8)(iv) (footnote 
5)).  
5 RAE = Retinol Activity Equivalents; 1 microgram RAE = 1 microgram retinol, 2 micrograms 
supplemental -carotene, 12 micrograms dietary -carotene, or 24 micrograms dietary -carotene, or 24 
micrograms dietary -cryptoxanthin (see  101.9(c)(8)(iv) (footnote 3)).  
6 1 mg -tocopherol (label claim) = 1 mg -tocopherol = 1 mg RRR--tocopherol = 2 mg all-rac--
tocopherol (see  101.9(c)(8)(iv) (footnote 4)).  
 
  
   
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III.  Conversion Factors 
 
A.  Folate 
 
The 2016 RDI for folate is based on the RDA of 400 mcg of dietary folate equivalents (DFE) for 
men and women (Ref. 1). The term DFE was introduced by the NAM to take into account the 
differences in bioavailability between the naturally occurring folates in the reduced 
tetrahydrofolate form that are inherent components of conventional foods, and folic acid, the 
fully oxidized monoglutamate synthetic form of the vitamin, used to fortify conventional foods 
and often used as an ingredient in dietary supplements.  
 
Because folic acid is 85 percent bioavailable, but naturally occurring folate is only about 50 
percent bioavailable, folic acid is 1.7 (85  50) times more bioavailable. Therefore, the DFE 
folate is calculated as: 
 
mcg DFE  =  mcg naturally occurring folate + (1.7  mcg folic acid)  
 
DFE is the unit of measure for the labeling of folate in the Nutrition Facts label 
( 101.9(c)(8)(iv)) and the Supplement Facts label ( 101.36(b)(2)(i)(B)). In addition, when folic 
acid is added to conventional foods, folate must be declared as the percent DV folate based on 
mcg DFE, in addition to the quantitative amount of folic acid in mcg in parentheses ( 
101.9(c)(8)(vii)). Declaring the quantitative amount of folate in mcg DFE is optional. When folic 
acid is added to dietary supplements the quantitative amount of folate must be declared by 
weight in mcg DFE folate and the percent DV based on mcg DFE folate, in addition to the 
quantitative amount by weight of folic acid in parentheses ( 101.36(b)(2) and 101.9(c)(8)(vii)).  
 
Furthermore, for the Supplement Facts label, synthetic forms of folate other than folic acid (such 
as calcium or glucosamine salts of L-5-methyl-tetrahydrofolate (L-5-MTHF)) may be added.3 
We do not intend to object to a manufacturer using its own established conversion factors for 
such forms of folate, provided that the declaration is truthful and not misleading. Furthermore, 
we would not expect a conversion factor for any synthetic form of folate to exceed 1.7 
(comparable to folic acid), when reporting mcg DFE on the Supplement Facts label (81 FR 
33742 at 33908-09).  
 
 
   
                                                           
3 The only form that can be added to conventional food is folic acid under  172.345. 
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Examples of Conversion from Naturally Occurring Folate, Folic Acid, 
and Synthetic Folate to Dietary Folate Equivalents (DFE) 
 
CONVENTIONAL FOODS 
 
Example 1: A serving (85 g) of frozen spinach contains only naturally occurring folate (120 
mcg) 
 
Folate Conversion to mcg DFE 
 
Folate (mcg DFE) = Naturally occurring folate (mcg per serving)  1.0 (conversion factor for 
naturally occurring folate) 
 
Folate (mcg DFE) = 120 mcg  1 = 120 mcg DFE 
 
% DV Calculation 
 
% DV = [Folate (mcg DFE)  2016 RDI for folate (mcg DFE)]  100 
% DV = (120 mcg DFE  400 mcg DFE)  100 = 30%  
 
 
Label Declaration 
 
Declaring naturally occurring folate on a conventional food label is voluntary. If a manufacturer 
wants to report naturally occurring folate, the label declaration must be as follows, except that 
declaring the quantitative amount for folate in mcg DFE (e.g., 120 mcg DFE) is optional 
( 101.9(c)(8)(ii) and (c)(8)(iv)): 
 
Nutrition Facts 
    % Daily Value 
Folate     120 mcg DFE  30% 
   
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Example 2: A serving (40 g) of ready-to-eat breakfast cereal contains only folic acid (200 
mcg) 
 
Folate Conversion to mcg DFE 
 
Folate (mcg DFE) = Folic acid (mcg per serving)  1.7 (conversion factor for folic acid) 
 
Folate (mcg DFE) = 200 mcg  1.7 = 340 mcg DFE 
 
% DV Calculation 
 
% DV = [Folate (mcg DFE)  2016 RDI for folate (mcg DFE)]  100 
% DV = (340 mcg DFE  400 mcg DFE)  100 = 85%4 
 
Label Declaration 
 
Declaring folic acid on a conventional food label is mandatory when folic acid is added or when 
a claim is made about the nutrient ( 101.9(c)(8)(iv) (footnote 6)). The label declaration must be 
as follows, except that declaring the quantitative amount for folate in mcg DFE (e.g., 340 mcg 
DFE) is optional ( 101.9(c)(8)(ii) and (c)(8)(iv)): 
 
Nutrition Facts 
    % Daily Value 
Folate     340 mcg DFE (200 mcg folic acid)  90% 
 
 
                                                           
4 Note that when the Daily Value is presented on the Nutrition Facts label, this figure is rounded to 90% in 
accordance with  101.9(c)(8)(iii).  Similar differences between the DV Calculation and the % Daily Value in the 
partial Nutrition Facts mockups below result from this rounding provision.  For dietary supplements, the 
applicable rounding requirements differ, and the percentages based on RDIs shall be expressed to the nearest whole 
percent ( 101.36(b)(2)(iii)(C)).       
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Example 3: A serving (30 g) of enriched wheat flour contains a combination of naturally 
occurring folate (5 mcg) and folic acid (50 mcg)5 
 
Folate Conversion to mcg DFE 
 
Folate (mcg DFE) = [Naturally occurring folate (mcg per serving)  1 (conversion factor for 
naturally occurring folate] + [folic acid (mcg per serving)  1.7 (conversion factor for folic acid)]  
 
Folate (mcg DFE) = (5 mcg  1) + (50 mcg  1.7) = 90 mcg DFE 
 
% DV Calculation 
 
% DV = [Folate (mcg DFE)  2016 RDI for folate (mcg DFE)]  100 
% DV = (90 mcg DFE  400 mcg DFE)  100 = 23% 
 
 
Label Declaration 
 
When a food ingredient is enriched (e.g., enriched wheat flour that is an ingredient in a loaf of 
bread), the vitamins and minerals in the enriched ingredient are not required to be declared in a 
foods Nutrition Facts label ( 101.9(c)(8)(ii)(A)-(B)). On the other hand, if enrichment nutrients 
are added separately from the wheat flour as ingredients to another food, those nutrients (e.g., 
thiamin, riboflavin, niacin, iron, and folic acid) must be declared on the Nutrition Facts label ( 
101.9(c)(8)(ii)). 
 
Nutrition Facts 
    % Daily Value 
Folate     90 mcg DFE (50 mcg folic acid)  25% 
 
                                                           
5 According to the standards of identity, enriched flour must contain in each pound 2.9 mg of thiamin, 1.8 mg of 
riboflavin, 24 mg of niacin, 0.7 mg of folic acid, and 20 mg of iron ( 137.165(a)). In this example, the folic acid 
amount was calculated to conform to the standards of identity of enriched flour in which 1 pound = 453.6 g (Ref. 2) 
and assuming a 30 g serving size yielded 46.296 mcg of folic acid per serving. This value was rounded to 50 mcg of 
folic acid (recommended increment of nearest 5 mcg per serving (Ref. 3)). For standards of identity of other 
enriched products, see 21 CFR Parts 136 and 137. 
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DIETARY SUPPLEMENTS 
 
Example 4: A dietary supplement contains only folic acid (400 mcg per serving) 
 
Folate Conversion to mcg DFE 
 
Folate (mcg DFE) = Folic acid (mcg per serving)  1.7 (conversion factor for folic acid)  
 
Folate (mcg DFE) = 400 mcg  1.7 = 680 mcg DFE 
 
% DV Calculation 
 
% DV = [Folate (mcg DFE)  2016 RDI for folate (mcg DFE)]  100 
% DV = (680 mcg DFE  400 mcg DFE)  100 = 170% 
 
 
Label Declaration 
 
 Supplement Facts 
    % Daily Value 
Folate     680 mcg DFE (400 mcg folic acid)  170% 
 
 
 
 
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Example 5: A dietary supplement contains only synthetic folate (as calcium L-5-MTHF, 
200 mcg per serving) 
 
Folate Conversion to mcg DFE   
 
Folate (mcg DFE) = Synthetic folate (mcg per serving)  1.7 (conversion factor for synthetic 
folate 6) 
 
Folate (mcg DFE) = 200 mcg  1.7 = 340 mcg DFE                
 
% DV Calculation 
 
% DV = [Folate (mcg DFE)  2016 RDI for folate (mcg DFE)]  100 
% DV = (340 mcg DFE  400 mcg DFE)  100 = 85% 
 
 
Label Declaration 
Supplement Facts 
    % Daily Value 
Folate     340 mcg DFE   85% 
 
 
   
                                                           
6 For synthetic folate (e.g., calcium L-5- MTHF) the 1.7 conversion factor was used as an example. If a 
manufacturer uses its own established conversion factors, we would not expect the conversion factor to exceed 1.7 
(comparable to folic acid), when declaring mcg DFE on the Supplement Facts label (81 FR 33742 at 33908-33909).    
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Example 6: A dietary supplement contains naturally occurring folate (50 mcg), folic acid 
(100 mcg), and synthetic folate (as calcium L-5-MTHF, 150 mcg) per serving 
 
Folate Conversion to mcg DFE 
 
Folate (mcg DFE) = [Naturally occurring folate (mcg per serving)  1 (conversion factor for 
naturally occurring folate)] + [folic acid (mcg per serving)  1.7 (conversion factor for folic 
acid)] + [synthetic folate (mcg per serving)  1.7 (conversion factor for synthetic folate7)]  
 
Folate (mcg DFE) = (50 mcg  1) + (100 mcg  1.7) + (150 mcg  1.7) = 475 mcg DFE 
 
% DV Calculation 
 
% DV = [Folate (mcg DFE)  2016 RDI for folate (mcg DFE)]  100 
% DV = (475 mcg DFE  400 mcg DFE)  100 = 119% 
 
 
Label Declaration 
 
Supplement Facts 
    % Daily Value 
Folate     475 mcg DFE  (100 mcg folic acid)  119% 
 
   
                                                           
7 For synthetic folate (e.g., calcium L-5-MTHF) the 1.7 conversion factor was used as an example. If a manufacturer 
uses its own established conversion factors, we would not expect the conversion factor to exceed 1.7 (comparable to 
folic acid), when declaring mcg DFE on the Supplement Facts label (81 FR 33742 at 33908-33909).  
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B.  Niacin 
 
The term niacin refers to nicotinamide (nicotinic acid amide-NAD), nicotinic acid (pyridine-3-
carboxylic acid), and derivatives that exhibit the biological activity of nicotinamide. 
Furthermore, the amino acid tryptophan is available for conversion to NAD once protein 
synthesis needs are met and thus can contribute to meeting the RDA for niacin (Ref. 1). The 
tryptophan-to-niacin inter-conversion was considered previously in setting the RDA for niacin 
(Ref. 4). Therefore, the RDA for niacin is expressed in Niacin Equivalents (NE), allowing for the 
conversion of tryptophan to niacin (mean value of 60 mg tryptophan is equivalent to 1 mg of 
niacin): 
 
 
1 mg NE   =   1 mg niacin 
      60 mg tryptophan 
 
 
The NE can be estimated as follows: 
 
                 
mg NE  =  mg niacin + (mg tryptophan  60) 
 
 
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Examples of Conversion from Niacin and Tryptophan to  
Niacin Equivalents (NE) 
 
CONVENTIONAL FOODS 
 
Example 7: A serving (30 g) of macadamia nuts contains 1 mg niacin and 0 mg of 
tryptophan  
 
Niacin Conversion to mg NE 
 
Niacin (mg NE) = [Niacin (mg per serving)  1 (conversion factor from niacin to NE)] + 
[tryptophan (mg per serving)  60 (conversion factor from tryptophan to NE)]  
 
Niacin (mg NE) = (1 mg  1) + (0 mg  60) = 1 mg NE 
 
% DV Calculation 
 
% DV = [Niacin (mg NE)  2016 RDI for niacin (mg NE)]  100 
% DV = (1 mg NE  16 mg NE)  100 = 6% 
 
Label Declaration 
 
Declaring niacin on a conventional food label is voluntary. If a manufacturer wants to report 
niacin, the label declaration must be as follows, except that declaring the quantitative amount for 
niacin in mg (e.g., 1 mg) is optional ( 101.9(c)(8)(ii) and (c)(8)(iv)): 
 
Nutrition Facts 
    % Daily Value 
Niacin     1 mg  6% 
 
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Example 8: A serving (85 g) of canned tuna contains 5 mg niacin and 300 mg of tryptophan  
 
Niacin Conversion to mg NE 
 
Niacin (mg NE) = [Niacin (mg per serving)  1 (conversion factor from niacin to NE)] + 
[tryptophan (mg per serving)  60 (conversion factor from tryptophan to NE)]  
 
Niacin (mg NE) = (5 mg  1) + (300 mg  60) = 10 mg NE 
 
% DV Calculation 
 
% DV = [Niacin (mg NE)  2016 RDI for niacin (mg NE)]  100 
% DV = (10 mg NE  16 mg NE)  100 = 63%   
 
 
Label Declaration 
  
Declaring niacin on a conventional food label is voluntary. If a manufacturer wants to report 
niacin, the label declaration must be as follows, except that declaring the quantitative amount for  
niacin in mg (e.g., 10 mg) is optional ( 101.9(c)(8)(ii) and (c)(8)(iv)): 
 
Nutrition Facts 
    % Daily Value 
Niacin     10 mg  60% 
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DIETARY SUPPLEMENTS 
 
Example 9: A dietary supplement contains 14 mg of niacin and 0 mg of tryptophan per 
serving 
 
Niacin Conversion to mg NE  
Niacin (mg NE) = [Niacin (mg per serving)  1 (conversion factor from niacin to NE)] + 
[tryptophan (mg per serving)  60 (conversion factor from tryptophan to NE)]  
 
Niacin (mg NE) = (14 mg niacin  1) + (0 mg tryptophan  60) = 14 mg NE 
 
% DV Calculation 
 
% DV = [Niacin (mg NE)  2016 RDI for niacin (mg NE)]  100 
% DV = (14 mg NE  16 mg NE) 100 = 88 
 
 
Label Declaration 
 
Supplement Facts 
    % Daily Value 
Niacin     14 mg  88% 
 
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Example 10: A dietary supplement contains 14 mg of niacin and 240 mg of tryptophan per 
serving 
 
Niacin Conversion to mg NE  
Niacin (mg NE) = [Niacin (mg per serving)  1 (conversion factor from niacin to NE)] + 
[tryptophan (mg per serving)  60 (conversion factor from tryptophan to NE)]  
 
Niacin (mg NE) = (14 mg niacin  1) + (240 mg tryptophan  60) = 18 mg NE 
 
% DV Calculation 
 
% DV = [Niacin (mg NE)  2016 RDI for niacin (mg NE)]  100 
% DV = (18 mg NE  16 mg NE)  100 = 113% 
 
 
Label Declaration 
 
Supplement Facts 
    % Daily Value 
Niacin     18 mg  113% 
 
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C.  Vitamin A 
 
The previous RDI for vitamin A was expressed in International Units (IU), a measurement based 
on the biological activity or effect, where one IU of vitamin A activity had been defined as equal 
to 0.30 mcg of all-trans-retinol or 0.60 mcg of all-trans--carotene (Ref. 4). However, IU does 
not reflect the carotene:retinol equivalence ratio (81 FR 33742 at 33913). The new unit of 
measure, RAE, considers the vitamin A activity of -carotene in supplements to be half the 
activity of pre-formed retinol, and the vitamin A activity of dietary -carotene to be one-sixth of 
the -carotene in supplements (Ref. 5). Furthermore, carotenoids, such as -carotene, added to 
food is assumed to have the same bioconversion as those naturally occurring in foods (12:1) 
(Ref. 6). For the other dietary provitamin A carotenoids, -cryptoxanthin and -carotene, the 
RAE is set at 24 based on a vitamin A activity approximately half of that for -carotene (Ref. 5).   
 
1 mcg RAE = 1 mcg pre-formed vitamin A (retinol) 
                     2 mcg supplemental -carotene  
                     12 mcg dietary -carotene 
                     24 mcg of other dietary provitamin A carotenoids  
               (-carotene or -cryptoxanthin) 
See  101.9(c)(8)(iv) (footnote 3).  
 
 
FDA recommends that manufacturers apply the conversion factors listed in Table 2 to convert 
the amount of pre-formed retinol and provitamin A carotenoids directly from mcg to mcg RAE.  
 
Table 2. Conversion factors from pre-formed retinol and provitamin A carotenoids expressed in  
mcg to vitamin A (mcg RAE) 
From (mcg)  Conversion to Vitamin A (mcg RAE) 
Pre-formed retinol  1 
Supplemental1  
 
 
-carotene                                              2 
Provitamin A carotenoids: -
                                            4 
carotene or -cryptoxanthin2 
Dietary  
 
 
-carotene                                            12 
Provitamin A carotenoids:                         
                                          24 
-carotene or -cryptoxanthin 
1 The conversion factors for the supplemental form should be applied only to those supplements containing purified 
provitamin A carotenoids in oil. For supplements containing provitamin A carotenoids from a food source, their 
respective dietary conversion factor should be applied. 
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2  Even though a conversion factor for supplemental -carotene or -cryptoxanthin had not been explicitly stated in 
the NAM report (Ref. 5), FDA is providing a suggested conversion factor of 4:1 based on the extension of the 
rationale and the observation that the vitamin A activity of dietary -cryptoxanthin and -carotene is approximately 
half of that for -carotene (Refs. 7-8) to the supplemental forms of these two provitamin A carotenoids.  
 
   
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There is no direct conversion factor from the vitamin A declared on labels in IU to mcg RAE, 
only individual conversion factors for provitamin A carotenoids and pre-formed vitamin A 
(Table 3). Therefore, manufacturers may apply the individual conversion factors listed in Table 3 
only when the food product is not a mixture of provitamin A carotenoids and/or pre-formed 
retinol or when the proportion of the individual pre-formed vitamin A and provitamin A 
carotenoids are known.   
 
 
Table 3. Conversion factors from vitamin A (IU) to Vitamin A (mcg RAE) 
From  Source  Conversion to mcg RAE 
Pre-formed vitamin A (retinol) 
  0.30 
  Supplemental -carotene1  0.30 
Vitamin A (IU)  Dietary -carotene  0.05 
Dietary provitamin A carotenoids2:                         
   0.025 
-carotene or -cryptoxanthin 
1 We considered the historical application for the conversion factor of supplemental -carotene, in which 1 IU = 0.6 
mcg of -carotene (Ref. 4), followed by a second step conversion from mcg to vitamin A expressed as mcg RAE (1 
mcg RAE = 2 micrograms supplemental -carotene) (Ref. 5). 
2 1 IU = 1.2 mcg of other provitamin A carotenoids. 
 
 
CONVENTIONAL FOODS 
 
Example of Conversion from Carotenoids (mcg) and Pre-Formed Retinol 
(mcg) to  
to Vitamin A, expressed in  
Retinol Activity Equivalents (mcg RAE) 
 
 
Example 11: A serving of a food that naturally contains 15 mcg of retinol, 4,800 mcg of -
carotene, and 2,400 mcg of -cryptoxanthin  
 
Conversion from Carotenoids (mcg) and Pre-Formed Retinol (mcg) to Vitamin A (mcg RAE) 
 
Vitamin A (mcg RAE) = [retinol (mcg per serving) x 1 (conversion factor for pre-formed 
retinol)] + [-carotene (mcg per serving)  12 (conversion factor for -carotene)] + [-
cryptoxanthin (mcg per serving)  24 (conversion factor for -cryptoxanthin)]  
 
Vitamin A (mcg RAE) = (15  1) + (4,800  12) + (2,400  24) = 515 mcg RAE 
 
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% DV Calculation 
 
% DV = [Vitamin A (mcg RAE)  2016 RDI for vitamin A (mcg RAE)]  100 
% DV = (515 mcg RAE  900 mcg RAE)  100 = 57% 
 
 
Label Declaration 
 
Declaring vitamin A on a conventional food label is voluntary.  If a manufacturer wants to report 
vitamin A, the label declaration must be as follows, except that declaring the quantitative amount 
for vitamin A in mcg (e.g., 515 mcg) is optional ( 101.9(c)(8)(ii) and (c)(8)(iv)): 
 
Nutrition Facts 
    % Daily Value 
Vitamin A     515 mcg  60% 
 
 
 
Example of Conversion from Vitamin A (IU) to Vitamin A, expressed in 
Retinol 
Activity Equivalents (mcg RAE) 
 
 
Example 12: A serving (240 mL) of milk contains 500 IU of vitamin A  
 
Vitamin A Conversion from IU to mcg RAE 
 
Vitamin A (mcg RAE) = Vitamin (IU per serving)  0.3 (conversion factor for pre-formed 
retinol) 
 
Vitamin A (mcg RAE) = 500 IU  0.3 = 150 mcg RAE 
 
% DV Calculation 
 
% DV = [Vitamin A (mcg RAE)  2016 RDI for vitamin A (mcg RAE)]  100 
% DV = (150 mcg RAE  900 mcg RAE)  100 = 17% 
 
 
 
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Label Declaration 
 
Declaring vitamin A on a conventional food label is voluntary. If a manufacturer wants to report 
vitamin A, the label declaration must be as follows, except that declaring the quantitative amount 
for vitamin A in mcg (e.g., 150 mcg) is optional ( 101.9(c)(8)(ii) and (c)(8)(iv)): 
 
Nutrition Facts 
    % Daily Value 
Vitamin A     150 mcg  15% 
 
 
DIETARY SUPPLEMENTS 
 
Example 13: A dietary supplement contains 3,500 IU of vitamin A (100% as purified -
carotene in oil) per serving 
 
Vitamin A Conversion from IU to mcg RAE 
 
Vitamin A (mcg RAE) = Vitamin A (IU per serving)  0.3 (conversion factor for supplemental 
-carotene) 
 
Vitamin A (mcg RAE) = 3,500 IU  0.3 = 1,050 mcg RAE 
 
% DV Calculation 
 
% DV = [Vitamin A (mcg RAE)  2016 RDI for vitamin A (mcg RAE)]  100 
% DV = (1,050 mcg RAE  900 mcg RAE)  100 = 117% 
 
 
Label Declaration 
 
Supplement Facts 
    % Daily Value 
Vitamin A     1,050 mcg  117% 
 
 
   
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D.   Vitamin D 
 
Vitamin D, also known as calciferol, comprises a group of fat-soluble seco-sterols where the two 
major forms are vitamin D  (ergocalciferol) and vitamin D  (cholecalciferol). One IU of vitamin 
2 3
D has been previously defined as the activity of 0.025 mcg of cholecalciferol (Vitamin D ) in 
3
bioassays with rats and chicks (Ref. 9): 
 
1 mcg cholecalciferol = 40 IU vitamin D 
 
Vitamin D is considered a nutrient of public health significance, and so mandatory declaration of 
vitamin D is necessary to assist consumers in maintaining healthy dietary practices (81 FR 33742 
at 33891). The required unit of measure for vitamin D is mcg for both conventional foods and 
dietary supplements. It is also permissible to include the voluntary labeling of vitamin D in IU, in 
parentheses, next to the mandatory declaration in mcg units (81 FR 33742 at 33912-33913). The 
two major forms of vitamin D, vitamin D  (ergocalciferol) and vitamin D  (cholecalciferol), have 
2 3
been reported to exhibit identical responses in the body (Ref. 9), so for the purpose of converting 
from IU to mcg, we consider them to be bioequivalent. Table 4 shows the conversion factor from 
IU to mcg of vitamin D. 
 
 
Table 4. Conversion factor from IU to mcg of vitamin D  
From  Source  Conversion to mcg Vitamin D  
  Vitamin D (ergocalciferol) 
2 
Vitamin D (IU)  Vitamin D3 (cholecalciferol)  0.025 
Vitamin D (ergocalciferol + 
 
cholecalciferol) 
 
 
 
 
 
 
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  Contains Nonbinding Recommendations 
 
Examples of Conversion from IU to mcg Vitamin D 
 
CONVENTIONAL FOODS 
 
Example 14: A serving (240 mL) of milk that contains 100 IU of vitamin D 
 
Vitamin D Conversion from IU to mcg 
 
Vitamin D (mcg) = Vitamin D (IU per serving)  0.025 (conversion factor for vitamin D) 
 
Vitamin D (mcg) = 100 IU  0.025 = 2.5 mcg 
 
% DV Calculation 
 
% DV = [Vitamin D (mcg)  2016 RDI for vitamin D (mcg)]  100 
% DV = (2.5 mcg  20 mcg)   100 = 13% 
 
 
Label Declaration 
 
Declaring vitamin D on a conventional food label is mandatory ( 101.9(c)(8)(ii)). In addition, 
FDA allows manufacturers to voluntarily declare the vitamin D in IU, in parentheses, next to the 
mandatory declaration in mcg unit as follows: 
 
Nutrition Facts 
    % Daily Value 
Vitamin D     2.5 mcg (100 IU)  15% 
 
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  Contains Nonbinding Recommendations 
 
DIETARY SUPPLEMENTS 
 
Example 15: A dietary supplement contains 1,000 IU of vitamin D per serving 
 
Vitamin D Conversion from IU to mcg 
 
Vitamin D (mcg) = Vitamin D (IU per serving)  0.025 (conversion factor for vitamin D) 
 
Vitamin D (mcg) = 1,000 IU  0.025 = 25 mcg 
 
% DV Calculation 
 
% DV = [Vitamin D (mcg)  2016 RDI for vitamin D (mcg)]  100 
% DV = (25 mcg  20 mcg)  100 = 125%  
 
 
Label Declaration 
 
Supplement Facts 
    % Daily Value 
Vitamin D     25 mcg (1,000 IU)  125% 
 
E.  Vitamin E 
 
The 2016 RDI for vitamin E is based on the RDA of -tocopherol, the only form of vitamin E 
that is maintained in the blood and has biological activity (Ref. 10). -Tocopherol has eight 
stereoisomers (RRR-, RSR-, RRS-, RSS-, SRR-, SSR-, SRS-, SSS-), but only RRR--tocopherol 
occurs naturally in food. The synthetic form, all-rac--tocopherol, contains all eight 
stereoisomers in equal amounts and is only present in fortified foods and supplements. The 
vitamin E activity is limited to the 2R-stereoisomers that have a higher biological activity than 
the 2S-stereoisomers. Therefore, the four 2R-stereoisomers: RRR- (naturally occurring form of 
vitamin E) and the other three synthetic forms (RSR-, RRS-, and RSS-) of -tocopherol were 
considered when establishing the RDA for vitamin E. Table 5 shows the conversions factors 
from mg to mg of vitamin E (label claim). 
 
  1 mg -tocopherol (label claim)  = 1 mg -tocopherol 
                 = 1 mg RRR--tocopherol 
                 = 2 mg all-rac--tocopherol 
 
Manufacturers should apply the conversion factors listed in Table 5 when converting natural and 
synthetic vitamin E from mg to mg vitamin E (label claim).  
 
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  Contains Nonbinding Recommendations 
 
Table 5. Conversion factors from natural and synthetic vitamin E from mg to mg of vitamin E 
(label claim) 
From (mg)  Conversion to mg of Tocopherol (label claim) 
RRR--Tocopherol    1 
All-rac--Tocopherol   2 
 
Manufacturers could also apply the conversion factors listed in Table 6 when converting natural 
and synthetic vitamin E from IU to mg vitamin E (label claim).  
 
Table 6. Conversion factors from IU to mg of vitamin E 
From  Source  Conversion to mg 
-Tocopherol 
(label claim) 
 
Natural vitamin E (RRR--tocopherol) including its ester forms 
Vitamin E  0.67 
(RRR--tocopheryl acetate and RRR--tocopheryl succinate) 
(IU) 
   
Synthetic vitamin E (all-rac--tocopherol) including its ester 
forms (all-rac--tocopheryl acetate and all rac--tocopheryl  0.45 
succinate) 
 
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  Contains Nonbinding Recommendations 
 
 Examples of Conversion From mg of Natural Vitamin E (RRR--tocopherol) 
and Synthetic Vitamin E (all-rac--tocopherol) to mg Vitamin E (label claim) 
 
 
CONVENTIONAL FOODS8 
 
Example 16: A serving (240 mL) of a fortified beverage contains 10 mg of natural vitamin 
E (RRR--tocopherol) and 8 mg of added vitamin E9 (synthetic all-rac--tocopherol)  
 
Vitamin E Conversion  
 
Vitamin E (mg) = [(Natural vitamin E (mg per serving)  1 (conversion factor for RRR--
tocopherol)) + (synthetic vitamin E (mg per serving)   2 (conversion factor for synthetic all-rac-
-tocopherol))] 
 
Vitamin E (mg) = (10 mg  1) + (8 mg  2) = 14 mg 
 
% DV Calculation 
 
% DV = [Vitamin E (mg)  2016 RDI for -tocopherol (mg)]  100 
% DV = (14 mg  15 mg)  100 = 93% 
 
 
Label Declaration 
 
Declaring vitamin E on a conventional food label when vitamin E is added to food is mandatory 
because some of the vitamin E present is added as a nutrient supplement ( 101.9(c)(8)(ii)). The 
label declaration must be as follows, except that declaring the quantitative amount for vitamin E 
in mg (e.g., 14 mg) is optional ( 101.9(c)(8)(ii) and (c)(8)(iv)): 
 
Nutrition Facts 
    % Daily Value 
Vitamin E     14 mg  90% 
 
 
                                                           
8 The same calculation will apply for supplements containing both natural and synthetic forms of vitamin E. 
9 There might be instances where the natural form (RRR--tocopherol) is added to food.  
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  Contains Nonbinding Recommendations 
 
DIETARY SUPPLEMENTS 
 
Example 17: A dietary supplement contains 20 mg of synthetic vitamin E (all-rac--
tocopherol) per serving 
 
Vitamin E Conversion 
 
Vitamin E (mg) = Synthetic vitamin E (mg per serving)   2 (conversion factor for synthetic all-
rac--tocopherol) 
 
Vitamin E (mg) = 20 mg  2 = 10 mg 
 
% DV Calculation 
 
% DV = [Vitamin E (mg)  2016 RDI for -tocopherol (mg)]  100 
% DV = (10 mg  15 mg)  100 = 67% 
 
Label Declaration 
 
Supplement Facts 
    % Daily Value 
Vitamin E        10 mg  67% 
   
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  Contains Nonbinding Recommendations 
 
Examples of Conversion from IU to mg Vitamin E 
 
CONVENTIONAL FOODS 
 
Example 18: A serving (1 tablespoon) of corn oil contains 3 IU of vitamin E 
 
Vitamin E Conversion from IU to mg 
 
Vitamin E (mg) = Vitamin E (IU per serving)  0.67 (conversion factor for natural RRR--
tocopherol) 
 
Vitamin E (mg) = 3 IU  0.67 = 2.01 mg 
 
% DV Calculation 
 
% DV = [Vitamin E (mg)  2016 RDI for -tocopherol (mg)]  100 
% DV = (2.01 mg  15 mg)  100 = 13% 
 
 
Label Declaration 
 
Declaring vitamin E on a conventional food label is voluntary. If a manufacturer wants to report 
vitamin E, the label declaration must be as follows, except that declaring the quantitative amount 
for vitamin E in mg (e.g., 2 mg) is optional ( 101.9(c)(8)(ii) and (c)(8)(iv)): 
 
Nutrition Facts 
    % Daily Value 
Vitamin E     2 mg  15% 
28 
  Contains Nonbinding Recommendations 
 
DIETARY SUPPLEMENTS 
 
Example 19: A dietary supplement contains 35 IU of vitamin E per serving 
 
Vitamin E Conversion from IU to mg 
 
Vitamin E (mg) = Vitamin E (IU per serving)  0.45 (conversion factor for synthetic all-rac--
tocopherol) 
 
Vitamin E (mg) = 35 IU  0.45 = 15.75 mg 
 
% DV Calculation 
 
% DV = [Vitamin E (mg)  2016 RDI for -tocopherol (mg)]  100 
% DV = (15.75 mg  15 mg)  100 = 105% 
 
 
Label Declaration 
 
Supplement Facts 
    % Daily Value 
Vitamin E     16 mg  105% 
   
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  Contains Nonbinding Recommendations 
 
IV.  Paperwork Reduction Act of 1995  
 
This guidance refers to previously approved collections of information found in FDA 
regulations. These collections of information are subject to review by the Office of Management 
and Budget (OMB) under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520). The 
collections of information in  101.9 and 101.36 have been approved under OMB Control No.  
0910-0813. 
 
V. References 
 
The following references are on display at the Dockets Management Staff, Food and Drug 
Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852 and are available for 
viewing by interested persons between 9 a.m. and 4 p.m., Monday through Friday. References 
marked with an (*) are also available electronically at https://www.regulations.gov. References 
without asterisks are not on public display at https://www.regulations.gov because they have 
copyright restriction. Some may be available at the website address, if listed. References without 
asterisks are available for viewing only at the Dockets Management Staff. As of August 9, 2019, 
FDA has verified the Web site address for the references it makes available as hyperlinks from 
the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to 
Non-FDA Web site references after August 9, 2019. 
 
1.  Institute of Medicine. "Dietary Reference Intakes for Thiamin, Riboflavin, Niacin, 
Vitamin B6, Folate, Vitamin B12, Pantothenic Acid, Biotin and Choline," Washington 
D.C., National Academies Press; 1998. 
2.*  U.S. Department of Agriculture Agricultural Reserach Service, Nutrient Data Laboratory, 
Beltsville, MD. "Measurement Conversion Tables," 2016. Retrieved from: 
https://www.ars.usda.gov/northeast-area/beltsville-md-bhnrc/beltsville-human-nutrition-
research-center/nutrient-data-laboratory/docs/measurement-conversion-tables/. 
3.*  U.S. Food and Drug Administration. "Nutrition and Supplement Facts Labels: Questions 
and Answers Related to the Compliance Date, Added Sugars, and Declaration of 
Quantitative Amounts of Vitamins and Minerals: Guidance for Industry," 2018. 
Retrieved from: https://www.fda.gov/regulatory-information/search-fda-guidance-
documents/guidance-industry-nutrition-and-supplement-facts-labels-questions-and-
answers-related-compliance. 
4.  National Research Council. "Recommended Dietary Allowances, 10th Ed.," Washington 
D.C., National Academies Press; 1989. 
5.  Institute of Medicine. "Dietary Reference Intakes for Vitamin A, Vitamin K, Arsenic, 
Boron, Chromium, Copper, Iodine, Iron, Manganese, Molybdenum, Nickel, Silicon, 
Vanadium, and Zinc, Washington D.C., National Academies Press; 2001.  
6.  Institute of Medicine. "Dietary Reference Intakes: Essential Guide to Nutrient 
Requirements," Washington D.C., National Academies Press; 2006.  
7.  Deuel H.J., Jr., Greenberg S.M., et al. "Stereochemical Configuration and Provitamin A 
Activity; Neocryptoxanthin U." Arch Biochem. 1949;23:239-241. 
30 
  Contains Nonbinding Recommendations 
 
8.  Bauernfeind J.C. "Carotenoid Vitamin A Precursors and Analogs in Foods and Feeds." J 
Agric Food Chem. 1972;20:456-473. 
9.  Institute of Medicine. "Dietary Reference Intakes for Calcium and Vitamin D,"  
Washington D.C., National Academies Press; 2011.  
10.  Institute of Medicine. "Dietary Reference Intakes for Vitamin C, Vitamin E, Selenium, 
and Carotenoids,"  Washington D.C., National Academies Press; 2000. 
 
  
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