[SamBam]

The FDA definitely has requirements for anything advertising "zero calories," "no calories," "reduced calories" etc: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfr...

As for the "minimum calories," I've searched and either I'm out of date or was never correct: it seems like the FDA used to have a "80/120 rule": "beneficial nutrients" (vitamin, mineral, protein, total carbohydrate, etc.) must be at least 80% of the label value and "nutrients to limit" (calories, sugars, fats, etc.) must no greater than 120% of the label value. So calories could theoretically be lower than advertised, but not significantly higher.

The FDA seems to no longer have this rule, but calories is still on the "nutrients to limit" side, so the FDA would be mandating maximums, not minimums. My mistake.

[tspiteri]

Calories should not be considered as just "a nutrient to limit" in such a way that the number is only a maximum. I sometimes used to look at the energy value to choose a ready meal that had at least enough energy so that I would not remain hungry after eating; providing significantly less energy would leave me hungry.