Defining Natural - Part II

Last week, I told you about the FDA definition of "natural", their lack of one, and told you that they may start by looking at the USDA's. The branch of the USDA that is involved in allowing a natural claim is the FSIS - Food Safety and Inspection Service.

The FSIS first issued its guidance on November 22, 1982 in a Standards and Labeling Policy Memo (#055) stating that the term "natural" could be used in the labeling of meat & poultry when:

• The product does not contain any artificial flavor or flavoring, coloring, ingredient, or chemical preservative (as defined in 21 CFR 101.22), or any other artificial or synthetic ingredient; and
• The product and its ingredients are not more than minimally processed, which may include (a) those traditional processes used to make food edible, to preserve it, or to make it safe for human consumption, e.g. smoking, roasting, freezing, drying, and fermenting, or (b) those physical processes that do not fundamentally alter the raw product or that only separate a whole, intact food into component parts, e.g. grinding meat, separating eggs, pressing fruit.
• Relatively severe processes, e.g. solvent extraction, acid hydrolysis and chemical bleaching would clearly constitute more than minimal processing.

This sounds good - right? It is much more precise than the FDA definition, and the FSIS, like the FDA, reviews label submissions on a case-by-case basis for clarification. So why is it that even this definition is under review?

While I can't speak for the USDS/FSIS, it is probably because this still has a lot of grey areas. For instance, sodium, calcium, and potassium lactate (from corn sources) were allowed at levels up to 2% as flavoring. That is until the FSIS discovered that at that level, those products had an antimicrobial effect and they decided to re-evaluate those labeling claims individually for technical function and intended use. There are other ingredients that have similar stories. So in 2006 the FSIS took comments from the public and industry to try to clarify the term "natural" - they received over 12,000 comments that contained wildly divergent views on the topic.

So this year they decided to try again; they are soliciting comments until November 13, 2009 (if anyone wants to know how to submit their own comments send me an email & I'll send you the information). Some people want a very rigid definition, but that is difficult because it means the FSIS must think of almost every circumstance to close any potential loopholes; while others want flexibility so that the context can be considered (whether an ingredient is used as an antioxidant or as a flavor - like rosemary extract). And this is a complex issue; for instance, vinegar is a natural product, as is sea salt, but depending on their usage, it could mean a product cannot be legally labeled as natural.

So, what is the likely outcome for both the USDA/FSIS and the FDA? Well, with lawsuits and public comments pending, some changes will likely be forthcoming. We may very well end up with a system similar to that for organic products - kind of a tiered labeling system: 100% Natural, Natural, Made with all Natural Ingredients, Naturally Raised, etc.

I for one, am interested both as a consumer and as a food technologist, to see how these governmental agencies resolve this issue. And I hope you have gained a better understanding of the issues that impact the foods you consume and the regulations that govern their manufacture.

Defining Natural

I originally started this conversation on my post dated 11-20-08, but this topic just keeps reappearing, so I'm going to delve a bit deeper today.

Natural. Everyone can define this word - right? Per Webster, natural means: "existing in or produced by nature". Pretty simple & straightforward. So why is it that the FDA and USDA are having such trouble creating a working definition for this term? Perhaps it is because natural, when pertaining to foods, is not so easily defined. You see, there is a lot of grey area; there are many natural things, including chemicals, out there that you wouldn't want to be eating, so the dictionary definition simply won't work.

Let's start with the FDA. Way back in the early 1990's, they were petitioned to create a definition of "natural" for the industry to use. But in January of 1993, the FDA declined to establish a formal definition of natural and instead gave us this informal definition we've been using ever since. Natural means "nothing artificial or synthetic has been included in, or has been added to, a food that would not normally be expected to be in the food." [58 Fed. Reg. 2302, 2407 (January 6, 1993)]. Hence, the FDA decided not to attempt to restrict the use of the term natural except for added color, synthetic substances, and flavors.

Here's why this gets interesting. The FDA's Food Labelling and Standards department reviews the use of the term "natural" on a case-by-case basis since this statement of policy is just an advisory opinion and not a regulation. Or in plainer English, while companies and courts follow the FDA's opinion, it does not constitute federal law. One case currently being fought in the US courts is the against Snapple Beverage Corp. for their use of "All Natural" on their beverages containing high fructose corn syrup (HFCS).

In April 2008, the FDA's office of Nutrition, Labeling and Dietary Supplementation, stated that HFCS, due to the manufacturing process, would not qualify for a "natural" labeling term. But in July 2008, after clarification from one of the manufacturers about the process used to create HFCS, the FDA reversed its decision and declared that HFCS (when produced by the process submitted) can be considered "natural". (If anyone wants details on the processes involved, send me an email & I'll explain) Snapple argued that the FDA has authority regarding the naming & labeling of its drinks and the original court (New Jersey US District Court) found in favor of Snapple. Unfortunately, the US Court of Appeals for the Third Circuit last month reversed this decision and sent it back down for further review; their opinion is that the FDA's opinion has no force of law.

Unfortunately, there have been a number of other lawsuits (Ben & Jerry's, Cadbury Schweppes, Kraft, Arizona Beverage Co., etc.) also surrounding the use of the term "natural" (although not all concerning the use of HFCS). So what does this mean to consumers? Well, the industry is hoping it may force the FDA to adopt a formal policy regarding the definition of the term "natural". And the place they may start is with the USDA definition; but that will be my next post - so be sure to check back soon!

Good Gluten-free Alternatives - Part 3

I've saved the least well known options for this post, and the first one is seldom considered as human food in the US. This pretty looking picture on the left is millet (Panicum miliaceum). Yep, I said millet - but that's bird feed!

Why yes it is, but it is also people food (the pearle millet is anyway). In fact it is a staple in India, Africa, and China. It has been cultivated since prehistoric times. Its amino acid profile is better than wheat or corn and it can be used to make soups, stews, cooked cereal, and can be popped, roasted or sprouted.

To cook, roast 1 cup of millet in a saute pan in 1 tablespoon oil over moderately high heat and cook (stirring frequently) until it makes popping sounds and begins to turn golden. Remove the pan from heat. Then in a small saucepan bring 2 cups water to a boil and stir in the roasted millet. Cook covered, over low heat 20 minutes, or until water is absorbed. One cup of cooked millet has 207 calories, 6 grams of protein, 1.75 grams of fat, and 41 grams of carbohydrates, 2 grams of which are fiber. Millet has a good quantity of niacin (2.3 mg per cup of cooked) and zinc (1.58 mg per cup of cooked).

Sorghum (Sorghum spp.) is a cereal grain that is common to Africa and Asia. In fact it is one of the top five cereal grains in the world. It has been around since about 8000 BC and is related to millet. It is good nutritionally, but does lack the amino acid lysine.

You will most commonly find sorghum as either the flour or as a sweetener (like molasses). I've not seen the grain available whole in the stores in my area. However, if you could find it, 100 grams would contain 339 calories, 11 grams of protein, 3 grams of fat and 75 grams of carbohydrate, 6 grams of which are fiber. It is a good source of iron as well, containing 4.4 mg per 100g.

The last gluten-free alternative on my list is teff. Teff (Eragrostis tef) is a tiny grain, primarily found in Ethiopia where it is ground into a flour or consumed as a porridge. Teff has been domesticated since around 4000 BC.

You can find teff as whole seeds in some health food stores, but will probably find the flour is more common. When teff is cooked, it becomes gelatinous which allows it to be used to thicken soups, stews, gravies and even puddings. Of course the flour can be used to make gluten-free baked goods as well.

One cup of cooked teff contains 255 calories, 9.75 grams of protein, 1.5 g fat, and 50 grams of carbohydrate, 3 grams of which is fiber. It is considered a complete protein (all essential amino acids present), but is a bit low on the lysine. And teff has a good amount of calcium (387 mg per cup of cooked) and iron (15 mg per cup of cooked).

I hope you found this series on gluten-free alternatives interesting and that it peaked your interest in learning more about grain alternatives. The internet is a wonderful source of recipes using these lesser known ingredients, especially as the gluten-free market expands. As I've said many times before, please drop me a note with future topics you'd like me to cover - I'm always here to help you become more foodliterate!