Those of us in the USA who pay attention to labels and what appears on them are fairly well aware that the word “natural” really doesn’t mean much. The federal government, in the form of the Food and Drug Administration (FDA), has no definition in its books for the term. Well, they do have some kind of statement, but it’s sort of casual and broad and gives food manufacturers a great deal of leeway. That might change.

Last fall, the FDA took the step of responding to public opinion – and “the changing landscape of food ingredients and production” – and announced that it would explore the term “natural.” As part of the investigation, the agency put out the call for comments from the public. Just recently it announced that it is extending the comment period to May 10 of this year because of the complexity of the subject matter.

In the 1990s, the FDA issued non-legally binding guidance on “natural” labeling that permitted the use of the word as long as “nothing artificial or synthetic – including all color additives regardless of source – has been included in or added to a food that would not normally be expected to be in the food.” This guidance allows for foods or beverages with high fructose corn syrup or genetically-modified organisms (GMOs), for example, to still be labeled as natural. The policy, however, was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation. The FDA also did not consider whether the term “natural” should describe any nutritional or other health benefit.

Since that guideline was put into place, consumers’ concerns about what they eat and drink have increased. Research company NPD Group says, “There is emerging evidence that consumers are looking for foods to be in their pure form. Today, more than 30% of consumers are cautious about serving foods with preservatives compared to 24% 10 years ago, and the trend for additives follows the same progression. High fructose corn syrup and GMOs are two of the top-growing concerns in the United States. Much of their concern, however, stems from negative publicity, not science and lack of knowledge. An NPD report, Gauging GMO Awareness and Impact, shows one of the most common answers to the question of what is a GMO is ‘I don’t know’.”

That last comment from NPD might be just a little snarky. Entire nations are shunning GMOs for reasons that are easily looked up. High fructose corn syrup, while not proven to be a health risk per se, is certainly being studied by the medical and other industries because of suspicions that it is a risky additive.

Indeed, the FDA has agreed to re-examine its position on “natural” labeling precisely because of citizens who are concerned about what they eat and drink, and I’m willing to bet that they are slightly smarter than the “I don’t know” crowd. The FDA received three Citizen Petitions asking that the agency define the term “natural” for use in food labeling, and one Citizen Petition asking that the agency prohibit the term “natural” on food labels. The agency also observed that some US courts, as a result of litigation between private parties, have requested administrative determinations from the FDA regarding whether food products containing ingredients produced using genetic engineering or foods containing high fructose corn syrup may be labeled as “natural.”

Prominent natural and organic retailers have stepped into the national GMO discussion by  labeling “GMO-free” any products that meet the qualifications. Manufacturers have also decided to call out GMO-free foods.

“This may make consumers wonder if a product labeled ‘natural’ but not ‘GMO-free’ truly is ‘natural’,” says Darren Seifer, NPD food and beverage industry analyst. “This also supports updating the ‘natural’ definition to help consumers understand what can or cannot qualify for the label.”

Consumers rely on food labels to see what is and is not included in products, according to NPD’s food market research. Thirty-nine percent of Americans consume foods or beverages with an “all natural” or “natural ingredients” special label in an average week. Products with natural, organic, or whole grain claims are more likely to be consumed in an average week than those with a light/low-calorie label, pointing toward a shifting perception of health, according to NPD’s National Eating Trends, which tracks all aspects of US eating behaviors.

The current “natural” labeling guidance is in stark contrast to organic labeling, which has specific standards set out by the US Department of Agriculture (USDA). Organic products must meet environmental and animal treatment standards, and they cannot include GMOs.

“Marketers would be wise to initiate a dialogue with consumers to assuage concerns about particular ingredients,” says Seifer. “Education about how specific products and ingredients can fit into consumers’ daily lives also will go a long way in clearing up possible confusion about ‘natural’ foods messaging.”

Among the topics the FDA is seeking to explore as it gathers public comment are whether it is appropriate to define the term “natural,” and if so, how the agency should define it; and how the agency should determine appropriate use of the term on food labels.

What’s on that label?
Quite a few terms appear on food and beverage labels to promote the qualities of the products inside the package. Few people, probably, are aware that the use of some terms requires strict compliance with government regulation. Back in the old days, the brewer Guinness had a marketing slogan that was short, sweet and feel-good: “Guinness is good for you.”  That’s a no-no today – a food or drink can make no health claims, and “good for you” is a health claim. (Recently another brewer was ordered to remove the word “heart” from the label, even though its intended use was not a health claim. That’s how rigid the system is today.)

Here, in addition to “natural” as defined above, are some others:
• All Natural: Same as natural. They are interchangeable.
• Organic: Must consist of at least 95% organically produced ingredients; the other 5% must be approved on the National List provided by the USDA. They cannot be produced with any anibiotics, growth hormones, pesticides, petroleum or sewage-sludge based fertilizers, bioengineering or ionizing radiation. Each organic ingredient must be identified along with the name of the certifying agency.
• 100% Organic: Must consist only of organic ingredients and processing aids.
• Made with Organic Ingredients: Must consist of at least 70% organic ingredients, and none of the ingredients can be produced with sewage-sludge based products or ionizing radiation. And labeling cannot include the USDA seal or the word “organic” in any principle displays.
• Free Range/Cage Free: The animals cannot be contained in any way and must be allowed to roam and forage freely over a large area of open land. This labeling is said to be minimally regulated. The USDA requires only that the producer be able to demonstrate that the animals are allowed access to the outside and not contained, but applications and certification are not required.
• Grass Fed: Usually includes the label “free range” or “cage free,” but they are not necessarily connected. By definition, a “grass fed” animal is one that is raised primarily on ranges rather than in a feedlot, which means that they can be contained and still show this label, as long as they are allowed to graze. The USDA defines “grass fed” as it applies to labeling but does not regulate it in any way.



The author is president of Jack Kenny Media, a communications firm specializing in the packaging industry, and is the former editor of L&NW magazine. He can be reached by email at [email protected].