9, Number 6 - June 2008
IN THIS ISSUE:
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
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
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
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
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."
FoodNavigator-USA.com, 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.
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
"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
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
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.
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
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.
Guide to Food Labelling
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
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
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