In FDA regulations, Food labeling
When is it appropriate to use the term “natural” on your food label?

When is it appropriate to use the term “natural” on your food label? Image Source: Flickr user Anthony Albright.

Natural food is growing in popularity these days. We see labels that read “nothing artificial” and “100% natural” everywhere. Costco offers a wider selection of more wholesome food products, and even Walmart’s shelves are stocked with organic options. Ingredients that were once overlooked—like color additives, artificial sugars, and preservatives—are being viewed with skepticism and avoided by many people.

If you’re a food manufacturer looking to capitalize on this growing interest in healthier foods, you are likely considering using the term “natural” or some variant on your packaging. But in order to do so, you have to understand the legal implications of including “natural” on your food label and what this means for your product.

How the FDA Defines “Natural”

“Natural” is one of those terms that has proven difficult for the FDA to formally define—and as such, they haven’t. The governing body does, however, have a general policy as to what it considers “natural” to mean. Essentially, the FDA states that a product may be deemed “natural” if it doesn’t contain any artificial or synthetic additives or ingredients. It goes on to say that any product containing an ingredient that wouldn’t typically be found in that product can’t be deemed natural. Furthermore, “natural” doesn’t encompass any sort of processing—like pasteurization, irradiation, and use of pesticides—so one can still use the term if, for example, your product is processed in an unnatural way.

Even though this FDA definition isn’t formal, misleading uses of the term “natural” have resulted in multiple lawsuits in which food manufacturers have been sued. In 2011, a class-action lawsuit was filed against Kelloggs’ Kashi brand, which adorned their labels with claims including “all natural” and “nothing artificial.” It later paid a settlement of $5 million for misleading the public with such claims—it turned out that their products contained hexane-processed soy oil (containing a gasoline by-product) and calcium pantothenate, a calcium salt of vitamin B5 that acts as a stabilizer. Dozens of similar cases have been reported for misuse of the controversial term.

How to Proceed Carefully with the “Natural” Product Claim

As Kashi’s case showed, food manufacturers have a responsibility not to mislead the public with inaccurate label claims, even if there is no certification required by the FDA to use the term “natural.” So how can you use this term without risking repercussions? Let’s break down the specifics.

First, your product must not contain any artificial flavors or color additives. What if the color additive comes from a natural source, like beet powder, you may wonder? Nope, any additional color that is added purely to enhance or alter the aesthetic of a product is prohibited in order for a product to be considered “natural.” In the eyes of the FDA, it’s misleading.

Secondly, your product should be as close to nature as possible. This means it can’t contain any preservatives, even if they are naturally occurring. As with color additives, the rule of thumb is that if it isn’t expected to be found in the food, it shouldn’t be there. So, salt would be considered natural, while sodium nitrate wouldn’t.

Although the FDA states it doesn’t take into consideration the growing, manufacturing, or processing of food products, when it comes to the use of the term “natural,” these lines are blurry. As we saw with the Kashi case, the soy oil used in their product was made with a gasoline byproduct, ultimately making it unnatural even though this has more to do with the processing of the product. Therefore, it’s better to consult with a professional nutrition expert or contact the FDA directly if you are unsure whether your product fits the guidelines.

Be Aware of Change—Your Responsibility as a Food Manufacturer

It is important to note that the guidelines around natural food products are subject to change. In 2015, the FDA put out a request for public opinion on the use of the word “natural” on food products. In it, they asked if the public deemed it necessary for the FDA to define the term “natural,” and if so, how it should be defined. They also asked how the public would like to see the FDA judge the appropriate use of the term on food products. While the FDA has yet to make any official statements regarding the results, it is possible they are in the process of enforcing new rules around the use of the term or related terms.

Staying abreast of the rules can help you remain transparent and honest with your product labeling. For up-to-date information, try setting up a Google alert for FDA news regarding natural labeling or consult with a nutrition expert with experience in food manufacturing. At LabelCalc, we keep our blog up-to-date with the latest information on FDA compliance for food manufacturers.  While it is still formally undefined, using the term “natural” and other related terms properly will not only help you avoid any legal action taken against your company; it will also garner trust between your brand and consumers.

LabelCalc offers web-based nutritional analysis and FDA-approved label-making software specifically designed for food manufacturers. For all your label-related questions, contact us today.

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