FSC 8940

A-A-20178C

March 4, 2013

SUPERSEDING

A-A-20178B

December 12, 2012

COMMERCIAL ITEM DESCRIPTION

SUGAR SUBSTITUTES, NON-CARBOHYDRATE

The U.S. Department of Agriculture (USDA) has authorized

the use of this Commercial Item Description (CID).

1. SCOPE. This CID covers non-carbohydrate sugar substitutes, packed in commercially 

acceptable containers, suitable for use by Federal, State, local governments, and other interested 

parties, and as a component of operational rations.

2. PURCHASER NOTES.

2.1 Purchasers shall specify the following:

- Type(s), style(s), and package(s) of non-carbohydrate sugar substitutes desired (Sec. 3).

- Manufacturer’s/distributor’s certification (Sec. 9.2) or USDA certification (Sec. 9.3).

2.2 Purchasers may specify the following:

- Food defense section 9.1: Food defense system survey (FDSS) (Sec. 9.1.1), or Food 

defense addendum to plant systems audit (PSA) (Sec. 9.1.2), or (Sec. 9.1.2 with 9.2.1).

- Manufacturer’s quality assurance (Sec. 9.2 with 9.2.1) or (Sec. 9.2 with 9.2.2).

- Packaging requirements other than commercial (Sec. 10).

3. CLASSIFICATION. The non-carbohydrate sugar substitutes shall conform to the following 

list which shall be specified in the solicitation, contract, or purchase order.

Types, styles, and packages.

Type I - Saccharin (1,2-benzisothiazolin-3-one-1,1-dioxide) (C7H5NO3S) (21 Code of 

Federal Regulations (CFR) § 180.37)

Type II - Acesulfame potassium, also known as acesulfame K, (Potassium salt of 6-methyl-1-

2-3-oxathiazine-4(3H)-one 2,2-dioxide) (21 CFR § 172.800)

METRIC
A-A-20178C

2

Type III - Aspartame (1-methyl N-L-α-aspartyl-L-phenylalanine) (C14H18N2O5) (21CFR § 

172.804)

Type IV - Sucralose (1,6-dichloro-1,6-dideoxy-β-D-fructofuranosyl-4-chloro-4-deoxy-α-Dgalactopyranoside) (C12H19Cl3O8) (21CFR § 172.831)

Type V - Neotame (N [N-(3,3-Dimethylbutyl)-L-α-aspartyl]-L-phenylalanine-1-methyl ester) 

(21CFR § 172.829)

Type VI - Rebaudioside A purified from the leaves of Stevia rebaudiana (Bertoni) and streviol 

glycosides

Type VII - Siraitia grosvenorii Swingle fruit extract (SGFE) mogrosides

Style A - Granular

Style B - Tables

Style C - Liquid

Style D - Other (as specified by purchaser)

Package 1 - Envelopes/packets

Package 2 - Sticks

Package 3 - Bags/boxes

Package 4 - Canister

Package 5 - Bottle

Package 6 - Other (as specified by purchaser)

4. MANUFACTURER’S/DISTRIBUTOR’S NOTES. Manufacturer’s/distributor’s 

products shall meet the requirements of the:

- Processing guidelines (Sec. 5).

- Salient characteristics (Sec 6).

- Manufacturer’s/distributor’s assurance (Sec. 7).

- Regulatory requirements (Sec. 8).

- Quality assurance provisions: as specified by the purchaser (Sec. 9).

- Packaging requirements other than commercial: as specified by the purchaser (Sec. 10).

5. PROCESSING GUIDELINES.

5.1 Processing. The non-carbohydrate sugar substitutes shall be processed in accordance with 

Current Good Manufacturing Practices (21 CFR Part 110).

5.2 Food security. The non-carbohydrate sugar substitutes should be processed and transported 

in accordance with the Food and Drug Administration’s (FDA’s) Guidance for Industry: Food 
A-A-20178C

3

Producers, Processors, and Transporters: Food Security Preventive Measures Guidance.1 This 

guidance identifies the kinds of preventive measures food manufacturers, processors, or handlers 

may take to minimize the risk that food under their control will be subject to tampering or other 

malicious, criminal, or terrorist actions. The implementation of enhanced food security 

preventive measures provides for the security of a plant’s production processes and includes the 

storage and transportation of pre-production raw materials, other ingredients, and postproduction 

finished product.

6. SALIENT CHARACTERISTICS.

6.1 Ingredients. All ingredients, including food grade bulking and anticaking agents, used in 

the preparation of the non-carbohydrate sugar substitutes shall be of Food Chemicals Codex 

purity or U.S. Pharmacopeia-National Formulary quality, and meet the related FDA regulations 

on food additives or generally recognized as safe (GRAS) requirements.

6.2 Finished Product.

6.2.1 Type I, Saccharin. The Type I, Saccharin sugar substitute shall meet the requirements of 

21 CFR § 180.37.

6.2.2 Type II, Acesulfame-K. The Type II, Acesulfame-K sugar substitute shall meet the 

requirements of 21 CFR § 172.800.

6.2.3 Type III, Aspartame. The Type III, Aspartame sugar substitute shall meet the 

requirements of 21 CFR § 172.804.

6.2.4 Type IV, Sucralose. The Type IV, Sucralose sugar substitute shall meet the requirements 

of 21 CFR § 172.831.

6.2.5 Type V, Neotame. The Type V, Neotame sugar substitute shall meet the requirements of 

21 CFR § 172.829.

6.2.6 Type VI, Stevia. The Type VI, Stevia sugar substitute shall be manufactured from the 

species Stevia rebaudiana and meet the standards, requirements, and regulations adopted by FDA

for food additives, or generally recognized as safe (GRAS).

6.2.7 Type VII, SGFE mogrosides. The Type VII, SGFE mogrosides sugar substitute shall be 

manufactured from the species Siraitia grosvenorii Swingle and meet the standards, 

 

1

http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/FoodDefenseandEmergencyResponse/ucm083075.htm
A-A-20178C

4

requirements, and regulations adopted by FDA for food additives, or generally recognized as safe 

(GRAS).

6.2.8 Sweetness equivalent. Each package type shall contain and be labeled such that the 

contents are equal to 2 teaspoonfuls of sugar in sweetness.

7. MANUFACTURER’S/DISTRIBUTOR’S PRODUCT ASSURANCE. The manufacturer/

distributor shall certify that the non-carbohydrate sugar substitutes provided shall meet the salient 

characteristics of this CID, conform to their own specifications, standards, and quality assurance 

practices, and be the same non-carbohydrate sugar substitutes offered for sale in the commercial 

market. The purchaser reserves the right to require proof of conformance.

8. REGULATORY REQUIREMENTS. The delivered non-carbohydrate sugar substitutes

shall comply with all applicable Federal and State mandatory requirements and regulations 

relating to the preparation, packaging, labeling, storage, distribution, and sales of the noncarbohydrate sugar substitutes in the commercial marketplace. Delivered non-carbohydrate sugar 

substitutes shall comply with all applicable provisions of the Federal Food, Drug, and Cosmetic 

Act, the Fair Packaging and Labeling Act, and regulations promulgated thereunder.

9. QUALITY ASSURANCE PROVISIONS. Purchaser shall specify 9.3 or 9.4; purchaser 

may specify 9.1 with 9.1.1, or 9.1 with 9.1.2, 9.1.2 with 9.2.1, or 9.2 with 9.2.1, or 9.2 with 9.2.2.

9.1 Food defense. When required in the solicitation, contract, or purchase order, a FDSS shall 

be conducted by USDA, Agricultural Marketing Service (AMS), Fruit and Vegetable Program 

(FV), Specialty Crops Inspection Division (SCI). Food defense requirements include a 

documented and operational food defense plan that provides for the security of a plant’s 

production processes and includes the storage and transportation of pre-production raw materials 

and other ingredients and postproduction finished product. The plan shall address the following

areas: (1) food security plan management; (2) outside and inside security of the production and 

storage facilities; (3) slaughter, when applicable, and processing, including all raw material 

sources; (4) shipping and receiving; (5) storage; (6) water and ice supply; (7) mail handling; (8) 

personnel security; and (9) transportation, shipping, and receiving.

9.1.1 FDSS. When required in the solicitation, contract, or purchase order, a FDSS shall be 

conducted by USDA, AMS, FV, SCI. The FDSS verifies that operators of food establishments 

have implemented measures to minimize the risk of tampering or other criminal actions against 

the food under their control. (An AMS, FDSS verifies the participating company’s adherence to 

the FDA’s “Guidance for Industry - Food Producers, Processors, and Transporters: Food 

Security Preventive Measures Guidance.”) For further information, see Sec. 12.1 and 12.2.2.

9.1.2 Food defense addendum to PSA. When required in the solicitation, contract, or purchase 

order, a food defense addendum shall be conducted by USDA, AMS, FV, SCI auditors. This 
A-A-20178C

5

verifies that operators of food establishments have implemented measures to minimize the risk of 

tampering or other criminal actions against the food under their control. (An AMS, FDSS, PSA

verifies the participating company’s adherence to the FDA’s “Guidance for Industry - Food 

Producers, Processors, and Transporters: Food Security Preventive Measures Guidance.”) For 

further information, see Sec. 12.1 and 12.2.2.

9.2 Manufacturer’s quality assurance. When required in the solicitation, contract, or purchase 

order, the product manufacturer shall be required to provide evidence, by certificate, that the 

manufacturing plant has undertaken one of the following quality assurance measures within 12 

months prior to providing a bid, or no later than 10 business days from the date of awarding of 

the contract. Failure to provide this documentation within the proper time frame may result in 

the contract being terminated for cause.

9.2.1 PSA. A PSA conducted by USDA, AMS, or other audit performed by a third party 

auditing service is required within 12 months prior to the date of the awarding of the contract. 

(An AMS PSA verifies the manufacturer's capability to produce products in a clean sanitary 

environment in accordance with 21 CFR Part 110 - Current Good Manufacturing Practice in 

Manufacturing, Packing, or Holding Human Food, and verifies that the manufacturer has in 

place an internal quality assurance program.) (Perform with food defense addendum when 

required.)

9.2.2 Plant survey. A plant survey conducted by USDA, AMS, or other survey performed by a 

third party auditing service is required within 12 months prior to the date of the awarding of the 

contract. (An AMS plant survey audit verifies that, at the time of the survey, the manufacturer 

produces products in a clean sanitary environment in accordance with 21 CFR Part 110 -

Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food.)

9.3 Manufacturer’s/distributor’s certification. When required in the solicitation, contract, or 

purchase order, the manufacturer/distributor will certify that the non-carbohydrate sugar 

substitutes distributed meets or exceeds the requirements of this CID.

9.4 USDA certification. When required in the solicitation, contract, or purchase order that 

product quality and acceptability or both be determined, the SCI, FV, AMS, USDA, shall be the 

certifying program. SCI inspectors shall certify the quality and acceptability of the noncarbohydrate sugar substitutes in accordance with SCI procedures which include selecting 

random samples of the non-carbohydrate sugar substitutes, evaluating the samples for 

conformance with the salient characteristics of this CID and other contractual requirements, and 

documenting the findings on official SCI score sheets and/or certificates. In addition, when 

required in the solicitation, contract, or purchase order, SCI inspectors will examine the noncarbohydrate sugar substitutes for conformance to the U.S. Standards for Condition of Food 

Containers (7 CFR Part 42) in effect on the date of the solicitation.
A-A-20178C

6

10. PACKAGING. Preservation, packaging, packing, labeling, and case marking shall be 

commercial unless otherwise specified in the solicitation, contract, or purchase order.

11. USDA INSPECTION NOTES. When Section 9.4 is specified in the solicitation, 

contract, or purchase order, USDA certification shall include evaluation of the quality and 

condition of samples of non-carbohydrate sugar substitutes, and compliance with 

requirements in the following areas:

- Processing guidelines (Sec. 5)

- Salient characteristics (Sec. 6).

- Packaging requirements (Sec. 10 or as specified in the solicitation, contract, or purchase 

order).

12. REFERENCE NOTES.

12.1 USDA certification, FDSS, plant survey, and PSA contact. For a USDA certification, 

FDSS, plant survey, and PSA, contact the Chief, Inspection Branch, SCI, FV, AMS, USDA, 

STOP 0240, 1400 Independence Avenue, SW, Washington, DC 20250-0240, telephone 

(202) 720-2482, Fax (202) 720-0393, or via E-mail: Nathaniel.Taylor@ams.usda.gov.

12.2 Sources of documents.

12.2.1 Source of information for nongovernmental document is as follows:

Copies of the Food Chemicals Codex and U.S. Pharmacopeia may be purchased from: United 

States Pharmacopeial Convention, 12601 Twinbrook Parkway, Rockville, MD 20877-1790, 

telephone (800) 227-8772 or (301) 881-0666, Fax (301) 816-8148. Internet address: 

www.usp.org.

12.2.2 Sources of information for governmental documents are as follows:

Applicable provisions of the U.S. Standards for Condition of Food Containers are contained in 7 

CFR Part 42, the Fair Packaging and Labeling Act are contained in 16 CFR Parts 500 to 503, and 

the Federal Food, Drug, and Cosmetic Act are contained in 21 CFR Parts 1 to 199. These 

documents may be purchased from: Superintendent of Documents, New Orders, P.O. Box 

979050 St. Louis, MO 63197-9000. Credit card (Visa, MasterCard, Discover/NOVUS, and 

American Express) purchases may be made by calling the Superintendent of Documents on 

(866) 512-1800, (202) 512-1800. These documents may also be obtained free of charge on 

the Internet at: 

http://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR.
A-A-20178C

7

Copies of Guidance for Industry - Food Producers, Processors, and Transporters: Food Security 

Preventive Measures Guidance is available online from: FDA, CFSAN on the Internet at: 

http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocument

s/FoodDefenseandEmergencyResponse/ucm083075.htm.

Copies of this CID, the U.S. Standards for Condition of Food Containers (7 CFR Part 42), and 

beneficial comments, recommendations, additions, deletions, clarifications, etc. and any data 

which may improve this CID are available from and/or provided to: Chief, Standardization

Branch, SCI, FV, AMS, USDA, STOP 0240, 1400 Independence Avenue, SW, Washington, 

DC 20250-0240, telephone (202) 720-5021, Fax (202) 690-1527, via E-mail: 

CIDS@ams.usda.gov or on the Internet at: 

http://www.ams.usda.gov/CommercialItemDescription.

Copies of this CID are also available online at: ASSIST Online (https://assist.dla.mil) or 

ASSIST Quick Search (https://assist.dla.mil/quicksearch) or from the Standardization 

Documents Order Desk, Defense Logistics Agency (DLA) Document Services, Building 4D, 

700 Robbins Avenue, Philadelphia, PA 19111-5094. 

MILITARY INTERESTS: CIVIL AGENCY COORDINATING ACTIVITIES:

Military Coordinating Activity DOJ - BOP

HHS - NIH, IHS, FDA

Army - GL USDA - FV

VA - OSS

Custodians

Army - GL PREPARING ACTIVITY:

Navy - SA

Air Force - 35 USDA - FV

Review Activities

Army - MD, QM

Navy - MC

DLA - SS

The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, 

sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual's income is derived from any 

public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all 

programs and/or employment activities.) 

If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at 

http://www.ascr.usda.gov/complaint_filing_cust.html, or at any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the information requested in 

the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C. 

20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov.