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2 bacon flavors, 1 ingredient statement

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Posted 10 May 2018 - 06:43 PM

I am trying to determine how to handle a situation with a particular spice blend. My R&D department has come up with a blend that uses two different 'natural bacon flavors', but they both have different secondary ingredients. In the ingredients list can I just put 'natural bacon flavor' or do I need to list both of them with their secondary ingredients?




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Posted 10 May 2018 - 08:01 PM

This is what I found in regards to flavoring from the Food Standards and Labeling Policy Book provided by the USDA



FLAVORED WITH --: Any product with a standard in Section 9 CFR 319 and 9 CFR 381 of the regulations must meet that standard and may not be designated “flavored with.” If a product does not meet the standard as it appears in the Policy Book it can be labeled “Flavored with.” “Flavored with” can be anything from over 3 percent fresh meat or 2 percent cooked meat to below the standard for the product.




FLAVORING: Ingredients, e.g., thiamine hydrochloride, monosodium glutamate, disodium inosinate, disodium guanylate, hydrogenated vegetable oil, and other commonly used materials must be listed separately. Such ingredients as diacetyl, hexanal, ethyl alcohol, dimethyl sulfide, diallyl sulfide, and furfuryl mercaptan may be declared as artificial flavors or artificial flavorings without naming each. When spices and/or flavorings are presented on labels coming from foreign countries, the identity of the spices and/or flavorings must be made know.


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Posted 10 May 2018 - 08:59 PM

If none of the component ingredients need to be listed because the ingredient meets the standard to be called simply "natural bacon flavor", then you don't have to list them and both can be called the same thing.



21 CFR 101.22


(3) The term natural flavor or natural flavoring means 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. Natural flavors include the natural essence or extractives obtained from plants listed in 182.10, 182.20, 182.40, and 182.50 and part 184 of this chapter, and the substances listed in 172.510 of this chapter.

Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.


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Posted 18 May 2018 - 10:25 AM

I don't know about labeling of spice blends, but I am a flavor chemist and know about flavors.  You cannot call it "natural bacon flavor" unless it actually contains bacon (and no other flavor ingredients).  If your flavor has bacon in it with other natural flavors, you call it "natural bacon flavor with other natural flavors" (WONF) or "natural flavor."  If your flavor does not have bacon in it you call it "natural flavor" in your ingredient statement.  


Regarding the combination of the flavors:

Natural bacon flavor + natural bacon flavor = natural bacon flavor

Natural bacon flavor + natural bacon flavor WONF = natural bacon flavor WONF

Natural bacon flavor WONF + natural flavor = natural bacon flavor WONF

Natural flavor + natural flavor = natural flavor


Hope this helps. 


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