Food Label News ArchiveFood Label News SubscriptionsNutritional Analysis Food Labels - Food Nutrition Facts LabelsFood Consulting Company: Nutrition-Labeling-Regulatory

Volume 17, Number 6 - June 2017

Happy Summer Solstice from Food Label News. This month we cover the complexities of flavor and food label regulations. Whether it's whole ingredients, natural or artificial flavorings, or combinations of the three, there are specific rules for flavor naming. Read on to see which scenario relates to your products. We also expand on the 2016 Nutrition Facts label changes in the monthly Reader Q&A with information on rounding rules.

In this issue you'll find:

Flavors and FDA Food Labeling Rules

What's News in the Food Label Community

Reader Q&A: Nutrition Facts Rounding Rules


"I find your monthly newsletter, Food Label News, very helpful. Thanks for having such a great resource available."

– Rob Bradley 
Family Fresh Pack  


Karen C. Duester, President

Flavors and FDA Food Labeling Rules

Flavor labeling rules are some of the most difficult regulations to decipher for food labelers. What's tricky is when strawberry pastries contain both strawberries and strawberry flavoring. Can the pastries be called "strawberry pastries"? What if the pastries do not contain actual strawberries but are flavored with strawberry? Does it matter if the flavoring is natural or artificial? What if the package depicts a dancing strawberry?


Reader Favorites

What's in a Name? How to Choose the Correct Product Identity


The requirement for listing flavors in the ingredient statement is relatively straightforward. There are specific definitions for "natural flavors" and "artificial flavors" in 21 CFR 101.22 which dictates the ingredient name to use.

The confusing part about flavor labeling for many is when the flavor is included in the product name and/or graphics. What matters is how the "characterizing flavor(s)" – that is, the primary recognizable flavor(s) – are conveyed in the product name and on the package. When a flavor is included in the product name or implied through a graphic, specific regulatory copy must accompany the flavor name in all locations on the package and be presented in at least half the type size of the flavor name. Read on to learn which regulatory copy is required for each of the common scenarios.

Use of "flavored" – Strawberry flavored pastry or Strawberry naturally flavored pastry

Natural flavor is added; none of the characterizing ingredient is in the formula

Natural flavor is added; some characterizing ingredient is in the formula, but not enough to independently characterize the flavor

Use of "with other natural flavors" – Strawberry flavored pastry with other natural flavors

Natural flavors derived from multiple sources are added to enhance the characterizing flavor (for example: strawberries, raspberries and blueberries), and either none or not enough of the characterizing ingredient is in the formula

Use of "artificial flavors" – Strawberry artificially flavored pastry

Artificial flavors are added to simulate or reinforce the characterizing flavor, with or without the characterizing ingredient in the formula

Natural flavor not derived from the characterizing flavor name is added (natural raspberry flavor added, not strawberry flavor), and either none or not enough of the characterizing ingredient is in the formula

Use of "natural and artificial flavors" – Strawberry naturally and artificially flavored pastry

Though not specifically dictated in the CFR, when artificial flavors are required in the name and natural flavor is also in the formula, it is a common industry practice to list both in the regulatory copy

Use of actual ingredient name; does not require use of term "flavored" – Strawberry pastry

Characterizing ingredient is enough to independently provide flavor, even if natural flavor is added

Often foods will contain flavors as sub-ingredients of recipe components. These may or may not affect characterizing flavor naming. A chocolate chip with artificial vanilla flavor used as a sub-ingredient in a chocolate chip cookie would not require "artificially flavored" in the chocolate chip cookie product name. However, a strawberry pastry that contains a strawberry artificially flavored dried cranberry ingredient would need to include "artificially flavored" in the strawberry pastry name.

What's News in the Food Label Community

Declaration of trans fat (11+ comments)

Natural vs natural-type flavor (10+ comments)

Nutrition Facts for US and EU? (9+ comments)

Ingredient listing for spices (8+ comments)

Potassium 1% DV allowed? (9+ comments)

Join Food Label Community. Already a member, view Discussions.

Reader Q&A

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


What are rounding rules for actual quantities and % Daily Values for all mandatory nutrients declared in the Nutrition Facts label, per the new 2016 regulations? 
M.D., India, Food Manufacturer


Nutrients that were not changed in the 2016 Nutrition Facts label regulations follow existing rounding rules. Added Sugars follow the same rounding convention as Total Sugars, and FDA has released Draft Guidance with recommended rounding increments for Vitamin D, Calcium, Iron and Potassium.

See a quick one-pager on FDA rounding rules. More Reader Q&As.


What Matters in Food Labeling

Food Label News, now in its 17th year, is a monthly e-newsletter reaching over 10,000 subscribers around the world. We welcome your colleagues to subscribe for news and insights about food labels:


Your Virtual Food Label Partner

Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling, and regulatory support for more than 1,500 clients worldwide.
Our guarantee: 100% regulatory compliance. Contact us for the help you need now.

You may reprint all or part of this newsletter provided you attribute it to Food Label News and include a link to

© 2017. Food Consulting Company, Del Mar, CA. All rights reserved.