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Volume 9, Number 6 - June 2008


About Food Consulting Company

"On-time, accurate, thorough, and a pleasure to work with. Everything that a successful business has to be!"


~ Katalin Coburn
Peanut Better, Inc.

Greetings, Some of the most frequent questions to Food Consulting Company are related to using the term "natural" on food labels. This month Food Label News reports on how FDA, USDA, and Canada view "natural" on labels.

Q.  Is St John's wort allowed in a beverage at any level? 

           L.W., Beverage Company, California


A.  No, this botanical is not allowed for use as an ingredient in a beverage; this is explained in a January 30, 2001, "Dear Manufacturer" letter.  Read more: Reader Q&A page.

Submit a question for Reader Q&A (no charge).

"Natural" (or Not) on FDA-Regulated Food Labels

In February 2008, Food Label News reported on FDA's current and longstanding policy for "natural" on food labels; the newsletter reported that FDA has no plans to establish a regulatory definition for this term in the near future.

FDA's policy:

  • not to restrict the use of the term "natural" except for added color, synthetic substances, and flavors as provided in the Code of Federal Regulations

  • the use of "natural" means that nothing artificial or synthetic (including all color additives regardless of source) has been added

With this policy, there has been disagreement among stakeholders regarding the status of high fructose corn syrup (HFCS) as a natural sweetener. Those opposed to allowing HFCS natural sweetener status base their stand on the fact that chemical bonds are broken and rearranged in the manufacturing process. Those in favor take the stand that HFCS is made from corn, a natural grain product, and contains no artificial or synthetic ingredients or color additives and meets FDA's requirements for the use of the term "natural.", an internet news organization submitted an inquiry to FDA about HFCS and reported that FDA personnel examined the composition of the sweetener; the FDA personnel concluded that HFCS is produced using synthetic fixing agents and consequently FDA would object to the use of the term "natural" on a product containing HFCS.

Read article.

See Food Label News August 2005 and June 2006 for earlier reports on "natural."

Commentary: The debate about "natural" reaches far beyond the status of HFCS as a natural sweetener; partially hydrogenated soybean oil, autolyzed yeast extract, and modified corn starch are only a few of many other ingredients that may or may not be accepted by retailers who define "natural" for their market use. Food Consulting Company can help food companies establish labeling and positioning strategies for their product lines to convey fundamental product qualities of natural ingredients, while keeping claims compliant with FDA regulation and while avoiding negative attention from industry members and consumer-targeted media. Read and inquire about Regulatory Support.

"Natural" on USDA-Regulated Food Labels

Use of "natural" on USDA-regulated products is guided by the Food Safety and Inspection Service (FSIS). USDA-regulated products are those that contain greater than 2% cooked (or 3% raw) meat or poultry. FSIS initiated rulemaking to define the term "natural" in December 2006 and a public hearing was held. However, so far a regulatory definition has not been established; food labelers are to rely on the FSIS policy explained in the Food Standards and Labeling Policy Book (August, 2005).

The FSIS policy is that "natural" may be used on labeling for meat and poultry products provided that:

  • the product does not contain any artificial flavor or flavoring, coloring ingredient, or chemical preservative (defined in 21 CFR 101.22), or any other artificial or synthetic ingredient

  • the product and its ingredients are not more than minimally processed

Also per the policy, products claiming to be "natural" should carry a statement that explains what is meant by the term.

See FSIS Food Standards and Labeling Policy Book.

Commentary: USDA's policy for "natural" is considered to be more restrictive than FDA's policy for the term. Since labels for USDA-regulated foods require approval from FSIS prior to appearing on products, discrepancies in "natural" claim use are resolved before a product enters the market.

"Natural" on Canadian Food Labels

According to the Canadian Food Inspection Agency (CFIA) 2003 Guide to Food Labelling and Advertising (Chapter 4), foods or ingredients of foods submitted to processes that have significantly altered their physical, chemical or biological state can not be described as "natural."


  • a natural food or ingredient of a food is not expected to contain, or to ever have contained, an added vitamin or mineral, artificial flavor, or food additive

  • a natural food or ingredient of a food does not have any constituent or fraction thereof removed or significantly changed, except the removal of water

The Guide includes tables identifying processes affecting the natural character of foods with either a minimum or maximum of physical, chemical or biological change.

See CFIA Guide to Food Labelling and Advertising.

Commentary: Canadian rules for use of the term "natural" are more restrictive and tightly-defined than either U.S. FDA or USDA rules. For example, enriched flour is not a "natural" Canadian food ingredient. Food Consulting Company can help companies establish labeling and positioning strategies for their product lines for the Canadian market. Read and inquire about Regulatory Support.

At Your Service:  Since June 2006, Food Label News has provided 24 free answers to questions submitted by readers (such as the St John's Wort question above); see Reader Q&A page. Submit your question for consideration in an upcoming issue. The top three questions during 2008 (in terms of value and broad appeal to Food Label News readers) will be acknowledged with a $25 thank you check to the submitters in January 2009.

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