Our expert says:
Because Tables 1 and 2 do not list 'Sugar' as a nutrient for which a claim of 'Virtually free or free from' can be made, you cannot use this claim for a product that would under normal circumstances not contain any sugar. Also check page 34 item (13) regarding "no sugar added" claims. You may be able to make a comparative claim if your product contains less sugar than another similar product (see page 38), but I would recommend that you first ask the Department of Health, Directorate of Food Control before making any claims about the presence or absence of sugar.
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