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Volume 10, Number 11 - November 2009


Happy Anniversary Food Label News. As we start our 10th year of bringing you Food Label News, itís only natural that we celebrate with one of the most asked about topics: when to label a food as "natural." Last month we explored "natural" labeling for the U.S. and this month we address "natural" regulations in Canada.

We look ahead to highlight the yearís developments on what really matters for "Front-of-Pack" labeling next month.

In this issue you'll find:

Karen C. Duester, President


" The services provided by Food Consulting are essential to my client. I don't know how we would function without you."

Ė Marian Harding Cochran
Corporate Counsel for Leading Food Importer


"Natural" on Canadian Food Labels

According to the Canadian Food Inspection Agency (CFIA) 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 cannot 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.

Read last monthís issue of Food Label News about both FDA and USDA guidelines for "natural" in the U.S.

Keeping You Current

FDA letter to industry regarding point-of-purchase food labeling

Smart Choices Program postpones active operations

FDA seeks comments on ingredient name for "Evaporated Cane Juice"

Update on Canada's concerns over COOL as required by U.S. 2008 Farm Bill

USDA's National Nutrient Database SR22 now available

Revisions to FDA's Q&A guidance document for dietary supplement labeling

Canada's CFIA reminds about prohibited use of unenriched white flour

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. Therefore, it is impossible for a food that contains white flour to be labeled "natural" in Canada. For more information, see last link inset above right.

Disclosure Statements on Food Labels: Instructional Series
Part 3 of 10

This month's installment in our ten-part series details the requirements for "disclosure statements" on food labels. This 10-part 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., laboratory nutrition analysis serving the food industry.

View/print Part 3 of the series.

Donít forget to disclose your "disclosure statements." In our experience, disclosure statements are frequently overlooked on the labels we review for regulatory compliance. For more information about disclosure statements, see February 2009 Reader Q&A.

If you missed Part 1 or Part 2 of the series you can view and download them now. The pages from all parts will add up to the complete booklet.

Reader Q&A

Find answers to our readers' questions or send us your questions for an upcoming issue.


Can we label our agave syrup as a natural low glycemic sweetener in the U.S.?
A.B., Food Importer, Mexico


This question has two parts: "natural" and "low glycemic." As outlined in last       month's Food Label News, FDA does not restrict the term "natural" on food labels    provided the product is free of artificial flavors, chemical preservatives, or added colors (from any source). The FDA has not defined the term "glycemic." If you use the word "low" with "glycemic," you must have authoritative basis for the claim and include the reference on your label to ensure that the label is truthful and not misleading. Read more.

At Your Service

Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling and regulatory support to ensure 100% compliance with FDA regulations. With over 1,000 clients worldwide, Food Consulting Companyís services are ideal for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs.

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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