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Volume 10, Number 10 - October 2009


About Food Consulting Company

" You are my rockstar for today! The collaborative piece you developed with Silliker is fantastic. It's a well written, user-friendly resource with concise wording and easy flow. Bravo to you and your team."

Hanna Strowman
Trader Joe's

Dear Readers,  thank you for your positive support of the multi-part instructional series we launched last month. Based on your emails, this is already a hit! In addition to releasing installment two of the series, this month we are re-running articles about "natural" from our archive because of several recent inquiries. Read on... and continue to let us know what's on your mind. Send an email here.

Q.  Can enzymes used in dough conditioners in a bakery product be declared by a class name "enzymes" or must they be declared by the actual name of the enzymes in the Ingredient List?        R.C., Ontario, Canada


A.  The enzymes used in dough conditioners need to be listed in the ingredient statement by "common or usual name" (actual name of the enzyme). This is true for both USA and Canada. Read answers to other reader questions.

Send us your food labeling question for an upcoming issue (no charge). See Services if you need a speedy and confidential answer.

Food Label Claims: Instructional Series Part 2

This month's installment in our ten-part series differentiates allowable claims for conventional foods and dietary supplements. Print Series Part 2.

If you missed Part 1 of the series last month, you can find it here. The pages from all parts will add up to the complete booklet.

This instructional series is based on a 2009 publication titled "Silliker Nutrient and Health Claims U.S. Regulatory Guide" that was cooperatively developed by Food Consulting Company and Silliker, Inc. Food Consulting Company provided the technical content for the guide which is used by both companies for informational purposes with clients. Silliker provides laboratory nutrition analysis for Food Consulting Company clients when analytical data is needed or desired.

"Natural" 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.

Editor's Note: On September 14, 2009, an Advance Notice of Proposed Rulemaking (ANPRM) was published in the Federal Register. The ANPRM is soliciting comments to assist FSIS in defining the conditions under which the voluntary "natural" claim can be used in labeling for meat and poultry products. See Federal Register notice.

At Your Service: Plan now for 2010 regulatory support. With Food Consulting Company's FDA Regulatory Support in 2010, labelers will quickly move past technical information roadblocks that can slow label completion. Contact Us to set your plan in motion.

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