Defining the term ‘natural’ in food and beverage

The definition of what is a ‘natural’ food product has been a subject of discussion around the world for decades. The claim ‘natural’ belongs undoubtedly among the favourite descriptors of food products with marketers. Not all foods, however, would pass the test of consumers’ perception of which products can be still considered ‘natural’ and indeed not all foods fall in the scope of the legislators’ interpretation of the term ‘natural’.

In this article we hear exclusive analysis of the definition of ‘natural’ in the food and beverage industry. The ‘natural’ trend is undoubtedly one of the fastest growing and to look further into the regulation and legislation behind its popularity New Food asked Petr Menšík, Manager, EU Affairs at ECCO, The European Consulting Company. 

‘Natural’ by legislators

Only a few countries around the world have the term ‘natural’ and rules for its use defined in their legislation. EU legislation provides for the use of the term ‘natural’ in two cases.  Natural mineral waters are defined in Directive 2009/54/EC and Regulation (EC) 1334/2008 lays down the condition for the use of the description ‘natural’ for flavourings. For other foods and beverages there is not clearly defined what is and what is not ‘natural’ nevertheless the general food law^[1] stipulates that the labelling, advertising and presentation of food shall not mislead consumers.

Some EU Member States including the UK issued a guidance^[2] for the use the claim ‘natural’ to help manufacturers decide when these descriptions may be used and when they should not. According to the UK guideline the term “natural” means essentially that ‘the product is comprised of natural ingredients, e.g. ingredients produced by nature, not the work of man or interfered with by man. It is misleading to use the term to describe foods or ingredients that employ chemicals to change their composition or comprise the products of new technologies, including additives and flavourings that are the product of the chemical industry or extracted by chemical processes’.

In the United States the FDA has for a long time refused requests to define to term ‘natural’ explaining that ‘from a food science perspective, it is difficult to define a food product that is ‘natural’ because the food has probably been processed and is no longer the product of the earth’^[3] however the agency has not objected to the use of the term if the food does not contain added colour, artificial flavours, or synthetic substances. 

In 2015 due to the changing landscape of food ingredients and production, and in direct response to consumers who have requested that the FDA explore the use of the term ‘natural’ the agency asked the public to provide information and comments on the use of this term in the labelling of human food products. In the consultation, the FDA asked specifically for the public‘s view on how the agency should define ‘natural,’ how the agency should determine appropriate use of the term on food labels,  and whether it is even appropriate to define the term ‘natural’.

In the public consultation, which was open from November 2015 through May 2016, the FDA received 7690 comments submitted by individuals, consumer organisations and the industry. The responses include calls on the agency to define the term ‘natural‘, to define several degrees of naturalness (100% natural/ all natural, natural, made with natural) and on the contrary to prohibit the use of the term ‘natural‘ on food labels and in marketing these products. The FDA has not announced any time frame for any further steps, nevertheless the amount of received and varied comments indicates that this dossier will not be closed any time soon.

Identifying the lines

Why is the term ‘natural’ so difficult to define? What are the main obstacles? There are two aspects which need to be looked at when deciding whether a food or a food ingredient is ‘natural’ or not:  the source of the food and the processes used to manufacture the product.  As regards the source of ‘natural’ products, the most discussed question is whether food products containing ingredients produced using bio-engineered seeds can be considered ‘natural’.  

While some stakeholders could not imagine food containing GMOs being considered ‘natural’, others explain that if GMOs would be out of the scope of definition of natural there would be no difference between ‘natural’ and ‘organic’:  a description which is defined in legislation as that which prohibits the use of bio-engineered foods in these products.    

As regards processing, there are two main questions which are the subject of debates when defining the term ‘natural’.  There is a consensus that the processes which can be used in manufacturing of ‘natural’ foods exclude chemical processing but the line between physical and chemical processes is difficult to draw.  Another question is the use of processing aids which are not considered to be ingredients and which would in many cases not fulfil the criteria for being ‘natural’. Processing aids, which are intentionally used in the processing of foods to fulfil a certain technological purpose during treatment or processing, are not consumed as a food by themselves, however their use may result in the unintentional but technically unavoidable presence in the final product.

Given the result of the FDA public consultation and with regard to the fact that the International Standardisation Organisation also has the definition of ‘natural’ food ingredient on its agenda, it can be expected that the discussion on defining the term ‘natural’ will continue.

References

^{[1] Regulation (EC) No 178/2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authorityand laying down procedures in matters of food safety}

^{[2] https://www.food.gov.uk/sites/default/files/multimedia/pdfs/markcritguidance.pdf}

^{[3] http://www.fda.gov/AboutFDA/Transparency/Basics/ucm214868.htm}

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