Sugar-free without sweeteners
No calories. 0% sweetener. 0% sugar.
Drinks with no sugar and no sweetener
Sugar-free does not mean sweetener-free: which drinks contain no sugar nor sweeteners, and what the sugar tax and ingredients lists have to do with it.
‘Sugar-free’ is printed on many bottles and cans. This does not mean ‘unsweetened’: the label only refers to sugar – a drink may be labelled ‘sugar-free’ whilst still being sweetened with sweeteners. Anyone looking for drinks with no sugar or sweeteners should therefore check two sections of the label: the nutrition facts table and the list of ingredients. Here, we explain what the labelling means, which drinks contain neither, how the authorities assess sweeteners, and what the planned sugar tax has to do with it.
Sugar-free does not mean free from sweeteners
The EU Regulation on nutrition and health claims sets out what ‘sugar-free’, ‘low in sugar’ or ‘no sugar’ means on packaging. All three claims relate to sugar – they do not exclude sweeteners.
| Information on the label | Condition | Can sweeteners be used? |
|---|---|---|
| sugar-free | no more than 0.5 g of sugar per 100 ml | yes |
| low in sugar | no more than 2.5 g of sugar per 100 ml in drinks | yes |
| no added sugar | no added monosaccharides or disaccharides, nor any other foodstuff used for its sweetening effect; naturally occurring sugars must be declared | yes |
Sweeteners are food additives. There are 14 sweeteners authorised in the EU, including acesulfame K (E 950), aspartame (E 951), sucralose (E 955) and steviol glycosides (E 960a–d), as well as eight sugar substitutes such as sorbitol (E 420) and erythritol (E 968). Sweeteners are virtually calorie-free and are many times sweeter than sugar; sugar substitutes provide around 2 kilocalories per gram.
Read more: An overview of sweeteners and ‘zero’ drinks: what’s in them.
Which drinks contain neither sugar nor sweetener?
The German Nutrition Society (DGE) recommends drinking around 1.5 litres a day – ideally water or other calorie-free drinks such as unsweetened tea. According to the DGE, sugar-sweetened drinks contain around 80 to 100 g of sugar per litre. The following drinks, in particular, contain no sugar and no sweetener:
| Drink | Sugar | Sweeteners | What to look out for |
|---|---|---|---|
| Tap water | no | no | – |
| Mineral water, still or sparkling | no | no | – |
| Unsweetened tea | no | no | – |
| Flavoured water | depending on the product | depending on the product | If ‘sweetener’ appears in the list of ingredients, the drink is sweetened |
| Light and zero-calorie drinks | See the nutritional table | according to the DGE, contains | The words ‘contains sweetener(s)’ on the packaging |
| ACQUA REAPER, all varieties | no sugar in the list of ingredients | none listed in the list of ingredients | Energy – Blackcurrant & Pomegranate; contains caffeine |
Sweeteners: What the authorities say
In Europe, the safety of sweeteners is assessed by the European Food Safety Authority (EFSA), whilst worldwide it is assessed by WHO committees. Three current classifications:
- Sucralose (E 955): The EFSA has re-evaluated sucralose and published its opinion on 17 February 2026. The acceptable daily intake (ADI) of 15 mg per kilogram of body weight remains unchanged; the estimated intake from authorised uses is below this level.
- Aspartame (E 951): In July 2023, the International Agency for Research on Cancer (IARC) classified aspartame as ‘possibly carcinogenic’ (Group 2B); the expert panel JECFA left the acceptable daily intake of 40 mg per kilogram of body weight unchanged. According to the WHO, a 70 kg adult would have to drink more than 9 to 14 cans of diet soft drink a day to exceed this limit – assuming each can contains 200 to 300 mg of aspartame.
- Weight management: Since May 2023, the WHO has advised against using sweeteners for weight management. This recommendation is subject to certain conditions and does not apply to people with existing diabetes.
ACQUA REAPER contains no sugar or sweetener – ‘no sugar, no sweetener’ is the brand’s mission. Context and fact-check: Sugar or sweetener? And is sweetener carcinogenic?
What the sugar tax has to do with it
The Federal Ministry of Finance is planning a tax on sugary drinks; it has not yet been approved. According to the Hamburg Consumer Advice Centre, the policy paper envisaged a tax of 26 cents per litre for drinks containing 4.5 g of sugar per 100 ml or more, 32 cents for those containing more than 7 g, and 38 cents for those containing more than 10 g. Drinks containing sweeteners were also set to cost 26 cents per litre under this proposal. Finance Minister Lars Klingbeil ruled this out on 26 August 26: “I won’t do that. It won’t happen.”
The start date is also still to be confirmed: the Hamburg Consumer Advice Centre cites 2027, whilst ZDF cites 2028. According to all plans known to date, drinks containing no sugar nor sweeteners would not be subject to the tax. We summarise the current situation here: Sugar tax – what is planned.
Natural flavourings: flavour without sweetness
Flavourings are listed in the list of ingredients. If the label specifies the raw material – such as ‘natural grapefruit flavouring’ – at least 95 per cent of the flavouring must be derived from that foodstuff. If it simply states ‘natural flavouring’, it may also be derived from other natural raw materials.
On ACQUA REAPER products, the label for Pink Grapefruit states ‘natural grapefruit flavouring’, for Lime & Mint it states ‘natural lime flavouring’ and ‘natural peppermint flavouring’, and for Citrus it states ‘natural citrus flavouring’. Read more: Natural flavourings explained.
How to spot sugar and sweeteners on the label
- Nutritional information table: The row ‘of which sugars’ shows the sugar content per 100 ml. A product may only be labelled ‘sugar-free’ if it contains no more than 0.5 g.
- List of ingredients: The ingredients are listed in descending order by weight.
- Sweeteners: They are listed under the category ‘sweeteners’ along with their name or E number. The authorised sweeteners are numbered E 420, E 421 and numbers between E 950 and E 969.
- Note on the packaging: If a drink contains sweeteners, the packaging must state: ‘contains sweetener(s)’.
A detailed guide with examples: how to read an ingredients list.
ACQUA REAPER: sugar-free and without sweeteners
All six varieties contain no sugar and no sweeteners. According to the label, the Still and Sparkling varieties are table waters made from natural mineral water and carbon dioxide. According to the label, the flavoured varieties consist of water, carbon dioxide, natural flavouring and the acidifier citric acid; the nutritional information table lists 0 g of sugar and 1 kcal per 100 ml.
Energy – Blackcurrant & Pomegranate also contains caffeine (32 mg per 100 ml) and taurine. Due to its high caffeine content, it is not recommended for children or for pregnant or breastfeeding women.
- Lime & Mint – the flavour of lime and peppermint
- Citrus – citrus flavour
- Pink Grapefruit – Grapefruit flavour
- Energy – Blackcurrant & Pomegranate, with caffeine
- Still & Sparkling – table water in two varieties
Frequently Asked Questions
What can you drink that has no sugar and no sweetener?
Water – tap water or mineral water, still or sparkling – and unsweetened tea. These are precisely the drinks recommended by the German Nutrition Society as thirst-quenchers. When it comes to flavoured water, the list of ingredients is key: if it contains neither sugar nor sweeteners, the drink is neither sugared nor sweetened.
What does ‘sugar-free’ mean on a drink?
A drink may be labelled ‘sugar-free’ if it contains no more than 0.5 g of sugar per 100 ml – as stipulated by the EU Regulation on nutrition and health claims. The claim makes no mention of sweeteners. Whether any are present is indicated by the list of ingredients and the statement ‘contains sweetener(s)’.
Is ‘no added sugar’ the same as ‘sugar-free’?
No. ‘No added sugar’ means that no sugar or other sweetening ingredients have been added. Sugar that is naturally present may still be included and must be listed. Sweeteners and sugar substitutes are permitted in products labelled ‘no sugar’.
How can I tell if there’s sweetener in a drink?
The list of ingredients must include the category name ‘sweetener’ together with the name or E number, for example sucralose or E 955. In addition, the packaging must bear the statement ‘contains sweetener(s)’. The authorised sweeteners are numbered E 420, E 421 and numbers between E 950 and E 969.
Do Zero drinks contain sweetener?
According to the DGE, ‘Light’ and ‘Zero’ drinks contain additives such as sweeteners. You can easily recognise them by the words ‘contains sweetener(s)’ on the packaging and by the category name ‘sweeteners’ in the list of ingredients.
Are there any flavoured drinks that contain no sugar and no sweetener?
Yes. In that case, the flavour comes from flavourings and acidity, not from sweetness. The ACQUA REAPER flavours, for example, consist – according to the label – of water, carbon dioxide, natural flavouring and citric acid – with no sugar and no sweeteners.
Does the sugar tax also apply to sugar-free drinks?
As things stand, no. Although the Federal Ministry of Finance’s policy paper also provided for a tax of 26 cents per litre on drinks containing sweeteners, Finance Minister Klingbeil ruled out a tax on sugar-free drinks on 26 August 2026. The sugar tax has not yet been approved.
Sources
- European Commission: Nutrition claims (Annex to Regulation (EC) No 1924/2006), accessed 16 September 2026. food.ec.europa.eu
- Food Transparency (Federal Association of Consumer Organisations): Permitted: ‘No added sugar’ advertising – but still sweetened, as at 21 April 26. lebensmittelklarheit.de
- Hamburg Consumer Advice Centre: Sweeteners – Sweetness without regret?, as at 30 July 2026. vzhh.de
- Consumer Advice Centre: Sweeteners: What are sweeteners and sugar substitutes?, as at 26 June 25. verbraucherzentrale.de
- Consumer Advice Centre: Food labelling: What information must be included?, as at 26 March 25. verbraucherzentrale.de
- German Nutrition Society: It’s best to drink water, accessed 16 September 2026. dge.de
- EFSA: Re-evaluation of sucralose (E 955) as a food additive, EFSA Journal 2026, published 17 February 2026. doi.org
- World Health Organisation (WHO): Results of the hazard and risk assessment of aspartame published, 14 July 2023. who.int
- World Health Organisation (WHO): WHO advises against the use of non-sugar sweeteners for weight control in newly released guidance, 15 May 2023. who.int
- Hamburg Consumer Advice Centre: Sugar tax: What are the plans?, as at 25 August 26. vzhh.de
- ZDFheute: Sugar tax on zero-calorie drinks: Klingbeil says ‘No’, 26 August 26. zdfheute.de
- Food Clarity (Federal Association of Consumer Organisations): Extract or natural flavouring – what the differences are, 24 October 2018. lebensmittelklarheit.de
- ACQUA REAPER: Product labels for Pink Grapefruit, Lime & Mint, Citrus and Energy Blackcurrant, as at 07/26.
Sugar-free without sweeteners
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Six varieties with no sugar and no sweeteners — still, sparkling, three flavoured varieties and an Energy drink – Blackcurrant & Pomegranate. With all ingredients and nutritional values per 100 ml.