every single supplement brand’s attorneys and regulatory disagree with you.
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I am a supplement brand’s regulatory.
I understand that not declaring calories on amino acids is a standard industry practice. My argument is that this is incorrect. Do you have specific citations of the regulations that show the error in my logic?
My premise: just because individual amino acids dont make up a protein doesn’t mean you cant declare their calories. Thats non sequitur. The Atwater Factors are one method of many that can be used to determine calorie content, as per the CFR citation above. Also included in the acceptable methods is bomb calorimetry. We have bomb calorimetry data, among other sources, for amino acid calorie content.
Then your brand should have calories listed then on the label… 
Right?
Yes they should, but don’t, hence me delving into this topic.
You don’t have any actual counter arguments. You aren’t saying anything of substance about my logic, my interpretations of regulations or data, etc. Just interpersonal quips. I am asking where in Title 21 it says “the calorie content of amino acids may only be declared if the amino acids are incorporated into proteins” and nobody has anything to say. I will consider this thread to be over.
well I’m in a work meeting (slightly more important) so just scanning thru… didn’t feel a need to read your post any further
i also believe anything less that 5 cals per serving does not have to be listed
Not sure if it applies to this conversation or not but I remember from a @NutraBio video someone mentioning the different regulations of a “Supplement Facts” panel vs. a “Nutrition Facts” panel.
NutraBio was going to have a separate panel claiming calories from aminos, never finished it.
interesting conversation here. it’s been a while since I’ve looked at this topic, but I’m with Doug here