If you make an effort to buy sugar-free or other special-needs foods, you often are dealing with small companies. Even though they are small, they are REQUIRED to provide you proper documentation of their ingredients.
The page in question that many small food makers refer to is this one -
FDA Nutritional Requirements for Small Businesses
They read the part that says
The nutrition labeling exemptions found in 21 CFR 101.9(j)(1) and 21 CFR 101.36(h)(1) apply to retailers with annual gross sales of not more than $500,000, or with annual gross sales of foods or dietary supplements to consumers of not more than $50,000. For these exemptions, a notice does not need to be filed with the Food and Drug Administration (FDA).
This would seem to say that a small company - maybe a small chocolate shop - does NOT need to have their nutritional labels filled out. They don't need to provide ingredient lists or carb counts or sugar counts to the consumers. However, read on a little further!
If any nutrient content claim (e.g., "sugar free"), health claim, or other nutrition information is provided on the label, or in labeling or advertising, the small business exemption is not applicable for a product.
The bold is not mine - it is the FDA that has bolded that section!! They want to make this very clear. If the company is making a claim that this food is appropriate for a special diet, they have to prove it! This is about "truth in advertising". If a company promises its consumers that the food is sugar-free, the consumer has every right to see an actual nutritional chart and verify this information for themselves.
Also note below that. The FDA follows up to say:
These exemptions pertain only to nutrition labeling information, and have no effect on all other mandatory information (i.e., statement of identity, net quantity of contents, ingredient statement, and name and address of manufacturer, packer or distributor).
Ingredient lists are ALWAYS mandatory and must be available on everything you eat, so you can know if for example there are nuts in it if you have a nut allergy. So you must always have an accurate ingredient list AND an accurate nutritional breakdown for anything that says it's low sugar, sugar-free, low carb or so on.
Lisa Shea's Library of Low Carb Books