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Consumer interest in low-carbohydrate food products has intensified with increased awareness of obesity as a public health concern. This presents regulatory and analytical challenges. Current FDA regulations do not provide for use on food labels of claims that characterize the level of carbohydrates in foods.  In addition, the declaration of carbohydrate for food labeling purposes is calculated “by difference.”  For compliance purposes,  the amount of carbohydrate is determined as the difference between 100 and the sum of the crude protein, fat, ash and moisture.  This approach presents several problems.  A number of non-carbohydrate components (e.g.,  lignin, organic acids, tannins, waxes, some Maillard products) are included in “by difference” calculations.  Such calculations combine all of the analytical errors from the other analyses, and data may be highly variable.  Finally, a single value for carbohydrate  fails to identify the many types of food carbohydrates and does not allow for understanding potential physiological properties of these compounds. Such information is of increasing interest to consumers. The question arises as to how to define carbohydrate for food labeling purposes. Classifications based on chemical definitions may not readily translate into nutritional terms; those based on physiological properties may require that a singe effect be considered of overriding  importance and used as the basis of a classification scheme. Analytical challenges include identification and validation of the best methods to measure mono- and di-saccharides,  oligosaccharides, polyols, “available” and “resistant” starch, non-starch polysacccharides, and dietary fiber. FDA is developing an Advanced Notice of Proposed Rulemaking (ANPRM) to solicit public comment on how to apply recent NAS/IOM recommendations for food labeling.  Issues relating to labeling of carbohydrate will be included in this activity.