Natural Statement - What are the rules?
Hello IFSQN members,
I have been reader of your questions and find the IFSQN site one of the best resources I've found for practical as well as tough regulatory inquiries. I have one of my own today.
My company produces a food grade ingredient from plant based agricultural raw material. Several customers have requested a "Natural Statement". Does anyone have a clear understanding of the definition of natural? I've check on the FDA website, but it seems vague. We do use low dosage of sodium hypochlorite and peroxide for anti microbial treatment, but both are removed in the process in a wash stage. There are not residuals.
Thanks, Confused
Hi Bonnie and :welcome: .
I am not an expert in this field, but thought this thread might be at least interesting. http://www.ifsqn.com...mo-labeling-us/
Think the use of "natural" is a sticky wicket or at least for retail. Are they looking to verify that it is not synthetic?
:welcome: to IFSQN.
It's kind of hard to look up what you are looking for without knowing exactly what you make.
I'd think you might need to look up some sort of standard of identity for your product in the CFR and see if it exists.
Hi Bonnie,
Both USDA and FDA have very vague definitions for "Natural" and are somewhat different. Plus this is a risky claim to make. I have seen several lawsuits involving the "natural claim". I would suggest dealing with a reputable food lawyer. I know a couple if you wish to contact them. Best of luck here.
Sincerely,
Richard
USDA does have a definition for natural, but the FDA doesn't. There are literally dozens of lawsuits worth millions about "all natural", but none of them have ever gone to trial. All settled. You probably won't get sued if you're a small company with a low profile, but there are literally organizations set up whose purpose is only to sue people who use this term. They think of themselves as truth in advertising people, which I'll leave to y'all to judge.
There are some certifications which give a very strict definition of "natural", and you could get Certified Naturally Grown or Nature Seal. Even though I'm not excited about working to comply with another fad standard, I'm pushing for my R&D team to shoot for actual certifications instead of self declaring anything.
Thanks everyone for your expert feedback. I spent a lot of time researching the definition of natural. I found the following statement on the FDA's web page:
From a food science perspective, it is difficult to define a food product that is 'natural' because food has probably been processed and in not longer the product of the earth. That said, FDA has not developed a definition for use of the term natural or its derivatives. However, the agency has not objected to the use of the term if the food does not contain added color, artificial flavors or synthetic substances.
I've had several customer ask if our product is natural and I always ask them to define natural. That said, we do not make claims on our labeling.
Many thanks,
No longer confused
Thanks everyone for your expert feedback. I spent a lot of time researching the definition of natural. I found the following statement on the FDA's web page:
From a food science perspective, it is difficult to define a food product that is 'natural' because food has probably been processed and in not longer the product of the earth. That said, FDA has not developed a definition for use of the term natural or its derivatives. However, the agency has not objected to the use of the term if the food does not contain added color, artificial flavors or synthetic substances.
I've had several customer ask if our product is natural and I always ask them to define natural. That said, we do not make claims on our labeling.
Many thanks,
No longer confused
Dear Bonnie White,
So if the food contains any additives other than "added color, artificial flavors or synthetic substances" it can still be called FDA-Natural ? Really ?
Interesting but, to me, confusing. Then again, so is "Truth in Advertising". :smile:
Rgds / Charles.C