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What does “Natural” on a food label really mean?

Let the buyer beware

On November 8, 1990, President George Herbert Walker Bush (Bush I) signed into law the Nutrition Labeling and Education Act (NLEA), which mandated nutrition labeling information on most foods marketed to American consumers. The Act required the development of a nationally uniform food labeling and regulatory system, preempting many State and local labeling requirements.   

 

We previously discussed the basics of organic food labeling. You can find that article here.  Did you know that Organic standards are designed to allow some “natural substances” in organic farming to be labeled organic when they’re really not? Substances may be added as long as they are not considered to be “synthetic.” But the definitions are not clear cut and there are endless “exceptions” to the rule.
 
Read on…

 

The “Rules”
 
The Code of Federal Regulations (CFR) is the official print publication codifying the general and permanent rules published in the Federal Register by the federal government’s departments and agencies. The CFR is updated daily with the discussions and amendments appearing in the Federal Register. Together, these two publications establish the latest version of any given rule or proposed rule.

 

The CFR was first established in 1938.  It is divided into 50 titles, representing the industries regulated by the Federal government. Each title is divided into chapters bearing the agency’s name. Each chapter is further subdivided into many, many subsections and rules. Take a minute to skim the list of Titles. It shows the massive undertaking in the hands of the federal government (and why we need capable people in government….)

 

Title 7, subtitle B is reserved for regulations regarding Agriculture. Deep within this subsection is the National List of Allowed and Prohibited Substances, the criteria utilized to evaluate which substances or ingredients are allowed in organic food production. Reading through this extensive list, the particles are listed in several subcategories:

 

  • § 205.601 Synthetic substances allowed for use in organic crop production.
  • § 205.603 Synthetic substances allowed for use in organic livestock production.
  • § 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”
  • § 205.606 Nonorganically produced agricultural products that are allowed as ingredients in or on processed products labeled as “organic.”
  • § 205.602 Non-synthetic substances prohibited for use in organic crop production.
  • § 205.604 Non-synthetic substances prohibited for use in organic livestock production.
 
Honestly, nothing was surprising or obviously out of line. (However, if there are chemical specialists reading this and you find something egregiously toxic that I overlooked or missed the ramifications of, let me.) (And let the USDA know!)      
      
Under the category of non-organic substances allowed to be part of an organic label is item 12:

 

Flavors—Non-synthetic flavors may be used when organic flavors are not commercially available. All flavors must be derived from organic or non-synthetic sources only and must not be produced using solvents, carrier systems, or any artificial preservative.
What is a “natural flavor”?
 
When it comes to food, “natural” has become associated with healthy, nontoxic, and additive-free. Consumers equate “natural” with “organic,” believing they are synonyms, which they are not. They also believe that when they see the word “natural” on processed food labels, it contains no pesticides, artificial ingredients, or artificial processing. As far back as 2016, 73% of consumers surveyed said they seek out foods labeled with the word “natural,” despite the fact that there are no meaningful standards attached to the term.

 

In reality, “natural” simply means “from nature.” Figuring out what it really means when applied to flavor science is anything but straightforward.

 

Labeling confusion and “natural”
 
The FDA
 
Surprisingly, the FDA, which has been around since 1906, never developed a definition of a “natural” food. But this is not unique to the United States. Until recently, no major regulatory agency in the world overseeing labeling had a definition for “natural” in food either.

 

So, in November 2015, the FDA sought public comments on the use of the term “natural” in food labeling. Over 7,000 comments were submitted to the FDA, voicing wide opinions and many concerns about the use of the term “natural” on food products. After much debate and a long deliberation period, the FDA ruled that the label must include a statement defining how the term natural is defined; for example, the label only has to say “no sauces, coloring, or chemical preservatives have been added.”
 
The FDA’s regulations are listed under Title 21 of the CFR. Subchapter E lists how “flavors,” “flavorings,” and “natural flavors” are defined. This complicated document from the CFR was written to explain the definition of a “natural flavor” says this:

 

The essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional.

 

Huh? I don’t know about you, but that really didn’t clarify anything.
*While supplies last⬆︎
 
While food processors are required to list all ingredients on a food label, flavor manufacturers do not have to disclose their ingredients. They can use or add synthetic solvents, preservatives, emulsifiers, carriers, and other additives to a flavor that qualifies as “natural” under current regulations.

 

Many, if not most, ingredients labeled as “natural flavors” have never been fully analyzed.  A “natural flavor” may be derived from a truly natural source, such as oranges or strawberries, but the flavorings are usually a blend of compounds put together by flavor scientists (called “flavorists “or “flavor architects”). Truth is, both an ingredient labeled “natural flavors” or as “artificial flavors” are synthesized in laboratories, but “artificial flavors” most often come from petroleum and other inedible substances. A “natural flavor” can refer to anything that comes from a spice, fruit, vegetable, herb, bud, root, or leaf. Nutritionally, there is no difference between them.
 
According to a 2016 Consumer Reports article, the use of the word ‘natural’ is a deceptive marketing ploy to reel in unaware consumers. It’s not the same as organic. For example, among foods labeled with “Pure & 100% Natural,” were Wesson Vegetable Oil, which is made from soybeans genetically engineered to withstand herbicides,” and Kraft Natural Cheese, which contains cellulose (also known as wood pulp) and natamycin, an anti-fungal medication. 

 

Besides the requirement to add a descriptor of how the term natural is defined, “natural” isn’t regulated by the FDA at all.  

 

The USDA
 
The 2024 edition of the USDA’s Food Standards and Labeling Policy Book is 188 pages long. It lists an astonishing number of food items and how they are to be appropriately labeled.  For example, if a product is labeled “macaroni and cheese with ham,” the product must contain a minimum of 12% cooked ham. Another example is “meat sauce.” The product must contain at least 6% ground meat.

 

This is what the USDA says about natural claims (pg 109 of the policy book):

 

The term “natural” may be used on labeling for meat products and poultry products, provided the applicant for such labeling demonstrates that:

 

  • the product does not contain any artificial flavor or flavoring, coloring ingredient, or chemical preservative (as defined in 21 CFR 101.22), or any other artificial or synthetic ingredient; and
  • The product and its ingredients are not more than minimally processed.
 
Minimal processed includes:

 

  • Traditional processes such as smoking, roasting, freezing, drying, and fermenting, or
  • Physical processes that do not fundamentally alter the raw product and/or which only separate a whole, intact food into component parts, e.g., grinding meat, separating eggs into albumen and yolk, and pressing fruits to produce juices.
  • Relatively severe processes, such as solvent extraction, acid hydrolysis, and chemical bleaching, would clearly be considered more than minimal processing.
 
However, there is a slippery exclusion inserted next:

 

The presence of an ingredient that has been more than minimally processed would not necessarily preclude the product from being promoted as natural. Exceptions can be granted on a case-by-case basis if it can be demonstrated “that the use of an ingredient would not significantly change the character of the product to the point that it could no longer be considered a natural product.”
 
Another exception is that the name of an ingredient may be buried in the label. For example, when titanium dioxide is used with poultry salad, a “qualifying phrase” should appear under the product name, stating the product has been “artificially whitened” or “artificially lightened.”

 

So, apparently, something can be labeled “natural” when it is not.
How Big is the Market?
 
The flavor is the sensory impression of a food substance, and it is determined mainly by the chemical senses of taste and smell. A food’s flavor can be altered by adding artificial flavorings or by changing its smell.

 

The Food Flavor Market is estimated to reach $25.7 billion by 2025. It includes food, perfumes, and cosmetics. According to IndusryArc.com, the “natural flavors” industry is set to be the fastest-growing segment in the years ahead.

 

The synthetic flavor segment held the largest revenue share in 2019 due to the increased addition of artificial flavors to many food and confectionary items. The beverage segment is a large and growing segment within the flavor market. The rising consumption of flavored beer, flavored milk, canned juices, and energy drinks is driving this sector.

 

Many food and beverage manufacturing companies are starting to use botanical extracts instead of chemicals because consumers are demanding clean “natural flavors.” They are becoming more aware and, hence, more concerned about the long-term adverse health effects of artificial ingredients and food additives. However, the high prices of natural flavors may impact the growth of the segment.

 

The list of the Top 5 flavor manufacturers in the US are:

 

  • Givaudan
  • International Flavors & Fragrances Inc.
  • Firmenich SA
  • Symrise AG, and
  • Archer Daniels Midland Company.

 

Givaudan is the world’s largest flavor, fragrance, and active cosmetic ingredient manufacturer. Founded in 1895, it has 166 locations worldwide, with its headquarters near Geneva, Switzerland. Its growth has accelerated since 2008 through continual acquisitions. A custom-designed flavor can consist of 50 to 100 different compounds derived from natural and/or artificial sources. That’s why the products are considered to be proprietary trade secrets, are sold under strict confidentiality agreements, and why the precise ingredients remain unknown.

 

A smaller, but important flavoring company is Flavorman. Founded in 1992, it promotes itself as the benchmark for innovation in the beverage industry, having developed more than 80,000 beverage formulations over the last 30 years.

 

Bottom line
 
Stick with food labels that identify the product as “100% USDA organic.” Truly organic products are highly regulated. You can go back and review the labeling information again here.

 

I like what the American Academy of Lifestyle Medicine says about food and eating. With a bit of personal modification, this is the best diet:

 

  1. Eat real food. What comes in a can, box, or they had you out a window isn’t real food.
  2. Eat mostly (organically grown) fruits and vegetables.
  3. Eat clean meat – know your rancher or farmer.
  4. Drink filtered water (the type of filter is a different, big topic!
 
And … don’t each so much.
Source: ASPC table

 

Eggs
 
With labels like “organic,” “free-range,” “cage-free,” and “vegetarian fed” it’s hard to know which eggs are the best to buy. While food labeling should be simple and transparent, unfortunately, is mostly about marketing.

 

CONVENTIONAL EGGS
 
Conventional eggs are not the most ethical or nutritional eggs available. These birds are generally fed poor quality feed that often contains antibiotics and hormones. Hens live in stacked rows of cages and live in a space approximately the size of a sheet of paper. The vast majority of egg-laying hens are confined in battery cages. Unable to spread their wings, caged laying hens are among agribusiness’s most intensively confined animals.

 

Poor living conditions increase the risk of bacterial contamination.

 

Globally, non-typhoidal Salmonella is one of the most frequently documented causes of foodborne disease. In the US, it is the second most common cause of foodborne outbreaks, and around 20% of the illnesses caused by Salmonella are related to poultry, poultry products, and eggs. In a study from 2023, Salmonella contamination varies widely among egg-producing countries. Contamination in US is low, and reported to be 0.005%. In Europe, Salmonella contamination has been found to be about 0.37%, and in China, the world’s largest egg producer eggs, between 0.5% and 5.6% of eggs were found to be contaminated.

 

FREE-RANGE EGGS
 
Lines can get blurred when it comes to the free-range egg label. This is because organic eggs must be free-range eggs, but free-range eggs aren’t necessarily organic, as they do not need to be fed organic feed. The USDA only requires free-range eggs to come from chickens with limited access to a small fenced outdoor area.

 

Likewise, eggs labeled “vegetarian,” “antibiotic-free,” or “all-natural” don’t need to follow the same strict rules and regulations as organic eggs. Nobody really checks up on these farmers so,  it’s up to the facilities to set their own standards for what constitutes a “vegetarian” egg.

 

ORGANIC EGGS
 
Under the USDA Organic Certification Requirements, organic eggs must come from chickens that are fed only organic feed free of animal by-products, synthetic fertilizers, pesticides, or chemical additives. These chickens must not be given any antibiotics or additional hormones. 

 

Organic eggs must be laid by 100% free-range, cage-free chickens with access to an outdoor area, even if it’s small. Overall, organically raised hens offer the highest potential standard of animal welfare, making them the most ethical egg option available.

 

Organic eggs are also somewhat more nutritional sound, even though the industry says there is no difference. Since the hens are fed high-quality feed, more movement, and no drugs, they produce fresher eggs with more nutrients. The yolks of organic eggs have a richer orange color that tastes richer and healthier. After eating organic eggs, the eggs served in most restaurants taste like styrofoam in comparison.

 

While organic eggs may be more expensive, sometimes double the cost of commercial eggs, they’re worth it. Look for the USDA Certified Organic label on the egg carton to buy from farmers who follow the strictest standards.
Beef
 
NOTE: Grass-fed describes WHAT the animal is eating, whereas pasture-fed describes  WHERE the animal is being fed.

 

Organic means the cows ate only organic feed and were not given antibiotics or hormones.
  
  • Grass-fed.  Animals receive most of their nutrients from grass and forages (such as hay) throughout their life. However, the animal’s diet has nothing to do with whether or not it received hormones or antibiotics. In other words, just because it the meat is labeled grass-fed, doesn’t necessarily mean it is organic.

 

The American Grassfed Association (AGA), a non-governmental organization, developed an approval label to clear this concern. If the meat has an AGA label , it means the animal was raised in a pasture, only fed grass or hay, and was never treated with hormones or antibiotics. American Grassfed Association (AGA) is a producer-founded and run non-profit organization that supports American Family Farms and Ranchers through certification, advocacy, and education programs.

 

A list of AGA-approved providers can be found here.

 

  • Pasture-raised.  A pastured-raised animal must have had access to the outdoors for at least 120 days per year. According to USDA regulations, this label includes terminology that refers to only a particular animal. For example, the animal may have lived in a field or on a wide-open ranch, or it may have lived outside in a small pen. The USDA has not developed a labeling policy regarding hormones and antibiotics for pasture-raised products. 
 
Pork
 
Pigs intended for meat products must be raised organically from the last third of gestation and, like beef, without the use of antibiotics and growth hormone stimulants.  To be labeled USDA certified organic, the pork must not only come from pigs raised on organically certified farms but also be processed by a USDA certified organic processing plant.

 

There are four major aspects of USDA-certified organic regulations relating to pig production—source of animals, feed, healthcare, and living conditions. The only source animal piglets that can be sold as organic are those who whose mother (the sow) has been managed organically from the last third of gestation to birth (gestation ranges from 111 to 120 days.)  Federal organic regulations require that organic pigs have access to the outdoors, shade, shelter, exercise areas, fresh air, clean drinking water, and direct sunlight. Organic pigs must have access to clean, dry bedding. If the bedding is crop residue, it must be from organic crops.

 

Pork labeled as organic must come from pigs only fed an organic diet primarily consisting of organic grains and protein sources, including organic soybean meal. The animal feed must be 100% organically produced and without animal byproducts or daily drugs. GMOs, hormones,  and antibiotics are strictly prohibited, but vaccines are allowed….and they get many.

 

Sheep
 
As of Jan. 31, 2024, there were 5.03 million head of sheep in the United States, with the largest numbers being located in Texas, California, and Colorado. Even though sheep are produced in all 50 states,  most sheep ranches are located west of the Mississippi River while the eastern US supports many small operations. When it comes to the countries with the most sheep, the US isn’t even in the top 10.

 

Difference Between Lamb and Mutton? 

 

Lamb is meat from young sheep under one year of age. Lamb is said to have a very delicate, even slightly sweet, grass-fed flavor, and the meat is very tender. Lamb is usually 60-70% more costly. Mutton is the meat of mature sheep, harvested between 2 to 3 years of age. Mutton is said to have a robust, greasy, even gamey taste compared to true cuts of lamb.  Because the animal is older, the meat tends to be tougher and more “chewy.”

 

Most lamb meat sold in the US comes from older sheep.  The USDA does not have clear labeling rules that differentiate between lamb and mutton. Labeling the meat lamb, yearling, or mutton is left to producers to classify. Therefore, any sheep meat under 24 months at the time of harvest can be labelled as lamb which is actually mutton.

 

An astonishingly large and diverse number of products are made from sheep and their byproducts, from food to cosmetics and shaving cream to surgical sutures. Check out this American Sheep Industry Association flier to see the full list.
What about produce labels?
 
Produce can be called organic if it’s certified to have grown on soil that had no prohibited substances applied for three years prior to harvest. 

 

Also, products that are clearing not organic have no misleading labeling, except of they are labeled with Apeel. Another chemical that has been used on our produce since 1996 is called 1-MCP, which stands for methyl-cyclopropane, marketed under the name Smart Fresh. Sprayed on produce can extend the shelf life of produce, such as apples and oranges, for up to three years. This can block replication of bacteria on the surface of produce but also disrupt human and animal gut microbiome.

 

Other labels found on produce are called PLU labels, standing for Price-LookUp codes. They allow retailers to manage inventory, process customer checkout faster, and help manage the produce industry supply chain. The codes are assigned by the International Federation for Produce Standards (IFPS); more than 1,400 PLU codes have been assigned to various types of fruits and vegetables.  The labels can also identify if the produce is organic or conventionally grown.

 

  • A four-digit code starting with the number 3 or 4 (3000 or 4000 series) is used for conventionally grown produce. This means synthetic fertilizers, chemicals, and/or pesticides might have been used during the growth of the produce.
  • A five-digit code starting with the number 3 identifies fruits and vegetables that have been irradiated or electronically pasteurized.
  • A five-digit code starting with the number 6 identifies pre-cut fruits and vegetables.
  • A five-digit code starting with the number 8 is designated for fruits and vegetables that have been genetically modified or bioengineered.
  • A five-digit code starting with the number 9 is designated for organic fruits and vegetables.
 
·If the code contains more than five digits, it is not part of the IFPS standardized system.

 

Summary

 
The next time you go to the grocery store, spend a little more time reading food labels. Know that you know a little more how they are categorized, you can be an even better consumer for yourself and your family.


You may want to shop using the ASPC food shopping list. They say on their website, but it’s a place to start.

 

“Where to buy” information is kept up-to-date by individual companies; please contact the store or seller directly to confirm product availability.

 

*The ASPCA does not audit farms or ranches and instead relies on independent animal welfare certifications as the basis for evaluating different food brands in the marketplace.

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