All Eyes on FDA as Comment Period Closes for Use of the Term “Natural”

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The saga of how (or if) use of the term natural is regulated on food labeling entered a new phase this week, with the comment period closing for the public to submit recommendations to FDA about how the agency should treat “natural” claims. Several dietary supplement and food industry trade associations weighed in on the murky issue, and much of the discussion revolved around how natural should be defined in relation to organic.

FDA first announced on November 10 it would be seeking public comments on the use of “natural” claims on food labeling, an issue it has avoided addressing with a formal definition in the past. Without a clear meaning, the grey area surrounding natural labeling of food products has bred numerous lawsuits and widespread consumer confusion.

Following three citizen petitions asking for a formal definition of natural for use in food labeling, FDA invited the public to provide recommendations on whether it is appropriate for the agency to define natural, and if so, how natural should be defined.

The comment period closed on May 10 and several groups submitting comments just before the deadline, including the Council for Responsible Nutrition (CRN; Washington, DC). Aside from confirming that there should indeed be a formal regulatory definition for the term natural, CRN suggested that a tiered system of natural categories be created similar to what currently exists under USDA’s National Organic Program for the term organic.

“To foster transparency and flexibility, a definition for natural should include a tiered system for labeling different categories of natural products,” CRN wrote. “For example, USDA Organic products can bear claims in four defined categories: “100% Organic”; “Organic”; “Made With” Organic; or identification of organic ingredients in the ingredients list.”

CRN also noted that it should not just be raw agricultural commodities that are allowed to bear the term natural, but rather, “If an ingredient is a derivative of a “raw” natural product that has undergone processing, then the resulting ingredient should still be considered natural for use in food labeling.”

Are foods derived from biotechnology natural?

The Natural Products Association (NPA; Washington, DC) also submitted comments on natural labeling to FDA, agreeing with CRN’s call for a tiered system of labeling categories for natural ingredients similar to what’s currently in place for organic.

However, Dan Fabricant, PhD, NPA’s CEO, also emphasized the need to distinguish natural from organic in one key area. While USDA’s definition of organic prohibits GMO ingredients, Fabricant said the same should not be true of natural to ensure there’s a useful difference between the two terms. Under his proposed definition, natural would exclude synthetic ingredients, but foods derived from biotechnology could still qualify as natural.

“Since organic is heavily focused on pre-harvest, natural should be concerned with whether the food product was naturally sourced and whether natural processes were used in its refinement,” Fabricant wrote. “NPA supports that natural should be evaluated after harvest and focus instead on whether ingredients were sourced naturally and further refined using natural processes.”

And that’s just the tip of the iceberg. Dozens of other organizations and thousands of individuals submitted comments regarding natural during the comment period. The onus is now on FDA to decide how to best define natural on food labeling, if at all.

Read more:

FDA Requesting Comments on Use of the Term "Natural"

What If FDA Regulates “Natural” Claims on Food Labels?

Without a Regulatory Definition for Natural, Industry Still in Limbo

Michael Crane
Associate Editor
Nutritional Outlook Magazine
michael.crane@ubm.com