Fruit juice concentrate is the one sweetener where "does it count as added sugar?" has a genuinely split answer — and the split is not about the ingredient, it's about the arithmetic. Used as a sweetener, it counts. Used to reconstitute juice back to normal strength, it doesn't. Same ingredient, same ingredient-list wording, opposite treatment on the Nutrition Facts panel.
The actual rule. Under 21 CFR 101.9(c)(6)(iii), added sugars include "sugars from concentrated fruit or vegetable juices that are in excess of what would be expected from the same volume of 100 percent fruit or vegetable juice of the same type." That's a subtraction, not a judgment call. FDA worked the example itself in the 2016 Nutrition Facts final rule: if 15 grams of concentrated apple juice carrying 6 grams of sugars is added to sweeten an applesauce, and 15 grams of ordinary 100 percent apple juice would have carried 1.7 grams, then 4.3 grams counts as added sugars. FDA was blunt about the intent: "We consider foods sweetened with concentrated fruit or vegetable juices to be sugar-sweetened foods."
What doesn't count. The regulation carves out a short, specific list: frozen or powdered concentrate from 100 percent juice sold to consumers to reconstitute at home; concentrate counted toward the total juice percentage declaration or used for Brix standardization; and concentrate forming the fruit component of jellies, jams, preserves, and fruit spreads. Note what is not on that list: "it came from fruit." FDA explicitly declined a blanket exemption for fruit-derived sugars, writing that sugars from fruit "can be isolated..., concentrated..., and stripped of nutrients such that they are essentially sugars."
The gap worth knowing. A juice blend reconstituted to full strength declares zero added sugars — FDA's guidance says so directly. But that same product cannot legally call itself "no sugar added," because 21 CFR 101.60(c)(2)(ii) bars the claim for any product that "does not contain an ingredient containing added sugars such as jam, jelly, or concentrated fruit juice." So a 0 g Added Sugars line and a "No Sugar Added" front-of-pack claim are two different bars, and the concentrate clears one but not the other.
How to spot it on a label: "fruit juice concentrate," "white grape juice concentrate," "apple juice concentrate," "pear juice concentrate," or "fruit juice blend (from concentrate)." White grape and apple are the workhorses — nearly flavorless, cheap, and sweet, which is why they sweeten so many fruit snacks, yogurts, and bars that market themselves on fruit. Position in the ingredient list is your best tell: near the top of a snack food, it is doing a sweetener's job. Separately on juice itself, the AAP's 2017 policy statement recommends no juice before 12 months, at most 4 oz a day for ages 1 to 3, 4 to 6 oz for ages 4 to 6, and 8 oz for ages 7 to 18.