Food Flavor Labeling

Hello,

I am having a hard time interpreting the following from 21 CFR regarding flavors in food.

In the first paragraph: If a food doesn't contain any artificial flavor you can just write the name of the flavor and nothing else (i.e. "Strawberry", "Banana", "Vanilla")?

In the second paragraph: If you have a product that is expected to contain a certain ingredient (i.e. "Chocolate Cake"), but doesn't, you can simply add "Natural" and "Flavored" before (I.e. "Natural Chocolate Cake Flavored") ?

Any help would be greatly appreciated!

(1) If the food contains no artificial flavor which simulates, resembles or reinforces the characterizing flavor, the name of the food on the principal display panel or panels of the label shall be accompanied by the common or usual name of the characterizing flavor, e.g., "vanilla", in letters not less than one-half the height of the letters used in the name of the food, except that:

(i) If the food is one that is commonly expected to contain a characterizing food ingredient, e.g., strawberries in "strawberry shortcake", and the food contains natural flavor derived from such ingredient and an amount of characterizing ingredient insufficient to independently characterize the food, or the food contains no such ingredient, the name of the characterizing flavor may be immediately preceded by the word "natural" and shall be immediately followed by the word "flavored" in letters not less than one-half the height of the letters in the name of the characterizing flavor, e.g., "natural strawberry flavored shortcake," or "strawberry flavored shortcake".

I think you have it, but I feel in your example, it would probably be Natural Chocolate Flavored Cake, as I assume the chocolate is the artificial flavor. In the case of a non-cake product that use natural flavoring to taste like chocolate cake such as a  protein shake, you could just write it as Chocolate Cake (Natural Flavors)

Label Declaration Options: Artificial Flavor, Natural and Artificial Flavor, Natural Flavor, or full name of natural flavor ex. Pure Vanilla Extract, Natural Coffee Flavor, Natural Strawberry Flavor WONF, and/or Natural Pistachio Type Flavor.

For most food and beverage products and ingredients, the FDA does not define "natural".  It does, however, for flavors/extracts; it classifies them in several major categories, and the classification designations must appear in the flavor's name:

• Artificial - The flavoring ingredients were manufactured/synthesized (artificial), versus being derived from natural sources.
• Natural and Artificial - Some of the flavoring ingredients were extracted or derived from the named flavor, while some were manufactured/synthesized (artificial).  For example, a Natural and Artificial Peach Flavor, will contain some peach extractives, plus artificial flavor components.
• Natural - All of the flavoring ingredients were extracted or derived from natural sources, versus being manufactured/synthesized (artificial).  The non-flavoring ingredients are not required to be natural.

FDA regulations further classify natural flavorings into sub-categories:

• Natural or Pure - If the product's name includes the word "natural" or "pure", and does not include either of the terms "with other natural flavors" or "type", then all of the flavoring ingredients in the product came from the named flavor.  For example, all of the flavoring in our Pure Vanilla Extracts comes from vanilla beans, and all of the flavoring in our Natural Coffee Flavor comes from coffee beans.
• Natural Flavor With Other Natural Flavors - For this designation, some of the natural flavoring ingredients were extracted or derived from the named flavor, while the remainder were extracted or derived from natural sources, but not from the named flavor.  For example, in our Natural Strawberry Flavor WONF, some of the flavoring components were extracted from strawberries, while others were extracted or derived from other natural sources.
• Type - For this designation, none of the natural flavoring ingredients were extracted or derived from the named flavor, but all of them were extracted or derived from natural sources.  For example, none of the flavorings in our Natural Pistachio Type Flavor were extracted or derived from pistachios, but all of them were extracted or derived from natural sources.
• Organic - All of the flavoring ingredients and non-flavoring ingredients must be natural.  At least 95% of the ingredients (excluding water and salt) must be organic-certified.  There are a number of other regulations, including certification by a third-party agency that the flavor ingredients and processing method meet USDA National Organic Program regulations.

I think you have it, but I feel in your example, it would probably be Natural Chocolate Flavored Cake, as I assume the chocolate is the artificial flavor. In the case of a non-cake product that use natural flavoring to taste like chocolate cake such as a  protein shake, you could just write it as Chocolate Cake (Natural Flavors)

if the chocolate flavor is artificial, you couldn't call it "natural".

I want to make sure I understand it. Does this summarize it correctly:

If a food (i.e. Chocolate Cake) does NOT contain a certain amount of an actual ingredient that should be present (i.e. Chocolate), but DOES contain flavor derived from that food (i.e. Natural Chocolate Flavor), it be can declared as “Natural _____ Flavored” (i.e. Natural Chocolate Flavored Cake)