Vegan Natural Butter Flavor Labelling
Hello All!
I'm having trouble undertanding FDA's stance on natural flavor declaration on labels.
We are developing a Corn oil infused with natural butter flavor. The butter flavor is natural as in made from plants, but it does not contain any butter. Can I declare it as:
Corn oil, natural butter flavor or Corn oil, Natural flavor? Or should it be differently declared?
Thank you all!
Natural Flavor is the best option, it's what we always recommend for our customers. Because your butter flavor does not contain any butter, if you list the specific name on the label, it needs to say, "Natural Butter Type Flavor". Since uninformed consumers think there is something wrong with Type flavors and WONF (with other natural flavors) flavors, it is usually best to go with "Natural Flavor" to prevent any confusion. Additionally, you do not need to list any sub-ingredients for the flavor, unless it contains preservatives or colors.
I am onboard with Spidey with this. 21CFR101.22, 101.B.i.1-4 lays it all out pretty clear. Adding the word "butter" adds a lot of complication to the label. I added the link for your review. If you have questions around specific labeling requirements you could always send a question to FDA through Industry.Foods@fda.gov. They usually respond pretty timely and you can use their responses as law for your processes. They hold up and when I have something that I am unsure about I print out their responses and leave them in my policy binder as guidance.
CFR - Code of Federal Regulations Title 21 (fda.gov)
Make sure that your products, even though are natural, do not have any allergens as determined under FALCPA or they need to be labeled in their entirety and "natural flavors" won't be enough.
Cheers!
Actually, if the flavor contains an allergen "Natural Flavor" is still acceptable, you just have to add the allergen to your allergen declaration label.
One advantage of using "Type" flavors is that you can use them to avoid adding the named allergen to your product. For example, all but one of my company's nut flavors are nut-free "Type" flavors.