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.

Is That Natural?

Natural seems a simple enough word; the dictionary definition is simple: existing in or formed by nature. If only it were that simple when it comes to the food you buy. You see each governmental agency has its own definition, or lack of one and that can (and does) lead to quite a bit of confusion.

The Food & Drug Administration (FDA) in 1988 defined natural as: nothing artificial or synthetic has been added to or included in a food that would not normally be expected to be in the food. Since then the industry has asked numerous times for clarification and/or redefinition of the term "natural", but alas to date the FDA has refused.

The United States Department of Agriculture (USDA) uses a decision tree to determine the natural status of a food (well really just meat, poultry & eggs since those are under their jurisdiction). They ask the following questions:

1. Does the product contain an artificial flavor, coloring agent, chemical preservative, or any other synthetic or artificial ingredient? If the answer is yes, then the product cannot be labeled as natural.
2. Are the product and its ingredients minimally processed? If the answer is yes, then the product can be labeled as natural.

Seems like this is pretty straight forward - right? Well, no. Some of the problems here are with defining minimally processed. Does drying, roasting/cooking, lowering pH (adding an acid like lemon juice or vinegar), or pressure cooking cause a product to lose it ability to call itself natural? What about microbially fermented products like yogurt, cheese, beer or wine - are these natural? You get the point.

And if those weren't enough to cause confusion, the National Advertising Division of the Better Business Bureau had decided they want a voice in this discussion too. They define natural as depending on:

1. The origin of the ingredients
2. How the term "natural" is presented in the context of a challenged advertisement
3. And the reasonable customer expectation as to the meaning of the term "natural"

Ouch! No wonder there is so much confusion about such a simple little word. There is a growing amount of pressure by consumers to have terms such as "natural" standardized and believe me, the industry is on board with that. Sometimes the simple things in life just aren't that simple.