The FDA is seeking comments from the public on the use of “natural” in food labeling. They requested comments on a series of questions, some of which I will respond to here (and submit these comments to the FDA).
We invite interested persons to comment on the use of the term “natural” in the labeling of human food products, including when, if ever, the use of the term is false or misleading (FDA-2014-N-1207). We are particularly interested in responses to the following questions:
Should we define, through rulemaking, the term “natural?” Why or why not?
No. Natural has a commonly used definition and one that is more frequent. In both cases, natural cannot be applied to food. The first is “existing in or caused by nature; not made or caused by humankind.” In that regard, there is almost no food that is natural. All food is processed, in some way, before being eaten by humans. Humans have bred plants and animals for centuries (in some cases) to provide food. From chickens that lay an egg a day to the nine vegetables we get from Brassica oleracea.
The other definition of natural relates to whether something exists in the material universe or is super- (or supra-) natural. That is, something that does not exist in our material universe. Natural is like the word “chemical”, which frequently has negative connotations, when, in fact, every material thing is made of chemicals.
Neither of these, commonly used, definitions of natural can discriminate between any form of food stuffs. In effect, a law would have to define natural in an uncommon way, which would definitely confuse consumers.
Should we prohibit the term “natural” in food labeling? Why or why not?
Yes. All food is natural in that it exists within our natural world. On the other hand, all food is unnatural because it has been processed by humans in some way or form over recorded history.
If we define the term “natural,” what types of food should be allowed to bear the term “natural?”
If we are forced to define natural, then only food which has not been modified by humans at any point in history, nor processed in any way should be considered natural. For example, a deepsea fisherman could catch a tuna and eat a portion of raw tuna (frequently called shashimi) on the boat. That is natural as tuna have not been specifically modified by humans in any way, nor has the meat been processed in any way. Even freezing the meat for the trip to a shore processing station would remove the ability to call it natural, that is “not made or caused by human kind”.
Should only raw agricultural commodities be able to bear the term? Why or why not? Section 201(r) of the FD&C Act defines the term “raw agricultural commodity” as “any food in its raw or natural state, including all fruits that are washed, colored, or otherwise treated in their unpeeled natural form prior to marketing.”
Even though this may be law, natural is not defined specifically in Title 21. However, section 321 (3)A specifically notates a difference between “natural” and “human activities”. While this is relation to pesticides, it is the only place we can draw any conclusion about the intention of the word natural. Human activities would include everything from breeding specific varieties to farming, processing, and cooking any food material. As such, without significantly changing the current definitions of natural, no food can possibly meet the criteria of natural.
As such, a law should be passed that no food gets to use “natural” or the government should specifically state that the word “natural” is purely advertising and has no verifiable benefits or advantages to any food product.
Should only single ingredient foods, e.g., bottled water or bagged spinach, be able to bear the term? Why or why not?
No. Even bottled water is highly processed by human activities prior to bottling. Many brands of bottled water use water straight from municipal water systems. As such, these supplies have been treated chemically and physically before bottling. Even water providers that get their water from “mountain streams” must process the water to remove detritus, bacteria, and other contaminants.
If multi-ingredient foods should be able to bear the term, what type(s) of ingredients would disqualify the food from bearing the term? Please explain why such disqualification would be warranted.
We are interested in any data or other information to suggest that consumers associate, confuse, or compare the term “natural” with “organic” (the USDA Agricultural Marketing Service administers the National Organic Program, which enforces laws and regulations regarding certified organic foods). We are interested in data and other information about consumers’ understanding of foods labeled “natural” versus “organic.” Is the term “natural” on food labels perceived by consumers the same way as “organic?” Or is “natural” perceived by consumers to be “better” (or not as good as) “organic?” Please provide consumer research or other evidence to support your comment.
I believe, based on conversations, that natural is perceived slightly differently as organic. Part of that is a common misunderstanding of what organic means. For example, organic does not mean “no pesticides” or “healthier than conventional foods”. Natural is often used on products that would not meet the requirements for organic food, but are perceived by the public as being healthier, with no justification for that perception other than the word “natural” being present.
In multiple blind taste tests, for example, consumers cannot differentiate between organic and conventionally grown produce. Indeed, in this video people ate food from McDonald’s, but were told it was organic “fast food”. In every case shown, the tasters reported it as much better and healthier than McDonald’s. Purely because they were told it was “organic”.
If we were to revise our policy regarding the use of the term “natural” or engage in rulemaking to establish a regulatory definition for “natural,” should certain production practices used in agriculture, for example, genetic engineering, mutagenesis, hybridization, the use of pesticides, or animal husbandry practices, be a factor in defining “natural?” Why or why not?
A regulatory definition of natural must be discriminatory. That is, it must be able to differentiate between different varieties, sources, or processing of the same food stuff. However, in general, those definitions already exist and are used (or not) based on the perceived benefits from a marketing standpoint, not a source material or consumer benefit standpoint.
It is not difficult to imagine that a product labeled “natural” would sell significantly better than a product labeled “produced on a factory farm and processed by many machines”, even though the two products are exactly the same in every respect.
We are interested in any data or other information to suggest that consumers associate, confuse, or compare the term “natural” with “healthy.” We have a regulation that defines the term “healthy” when used as an implied nutrient content claim with specific conditions related to the food’s nutrient profile that must be met in order to use the term on the label or in labeling of a food (see § 101.65(d)). We are interested in data and other information about consumers’ understanding of foods labeled “natural” versus “healthy.” Is the term “natural” on food labels perceived by consumers the same way as “healthy?” Or is “natural” perceived by consumers to be “better” (or not as good as) “healthy?” Do consumers view “natural” and “healthy” as synonymous terms? Please provide consumer research or other evidence to support your comment.
Part of the problem with a label, even if the term natural is significantly redefined is that the other products without the “natural” label are immediately perceived as “unnatural”. That is, something that is bad.
Should manufacturing processes be considered in determining when a food can bear the term “natural?” For example, should food manufacturing processes, such as drying, salting, marinating, curing, freezing, canning, fermenting, pasteurizing, irradiating, or hydrolysis, be a factor in defining “natural?”
Should the term “natural” only apply to “unprocessed” foods? If so, how should “unprocessed” and “processed” be defined for purposes of bearing the claim? If the term natural should include some processing methods, what should those methods be? In making determinations related to processing, should one look at the process to make a single ingredient of afood, or does one evaluate the process done to the formulated finished food product (or both)?
The current policy regarding use of the term “natural” hinges in part on the presence or absence of synthetic ingredients. For example, under the current policy synthetic forms of Vitamin D would not be used in a food claiming to be “natural,” whereas naturally sourced Vitamin D (e.g., from salmon or egg yolks) could be. Should the manner in which an ingredient is produced or sourced affect whether a food containing that ingredient may be labeled as “natural?” Please explain your reasoning.
What can be done to ensure that consumers have a consistent and accurate understanding of the term “natural” in food labeling to ensure that it is not misleading?
What are the public health benefits, if any, of defining the term “natural” in food labeling? Please provide supporting data and other information to support your comment.
Should “natural” have some nutritional benefit associated with it? If so, what should be the benefit? What nutrients should be considered? What data are available to support the association between “natural” and a given nutritional benefit, and/or between “natural” and certain nutrients?
I believe that the label “natural” or “all natural” is purely a marketing scheme to promote the idea of a product being healthy. By many definitions of natural, fortified breakfast cereal is non-natural. However, fortified cereals are significantly healthier than many cereals and similar products labeled “all natural”. One only has to review the nutrition information to see that this is true.
For example, compare Venetian Vineyard Granola (nutrition information) to classic Cheerios (nutrition information). Cheerios was even more nutritious before going non-GMO.
Comparing 1 cup of each (which is actually twice the serving size of the granola cereal) shows that Cheerios has 1/4 the calories and 1/10th calories from fat. True, there is 7 times the sodium in cheerios, but there is only 1/14th the sugar. Cheerios has 4 more vitamins and minerals than the granola. Of the ones shared between the two cereals Cheerios has more in all but phosphorus and magnesium. Missing from the granola are vitamins such as B12, niacin, and D. Missing from Cheerios are minerals such as copper and selenium and vitamins B5 and E. In many respects, Cheerios is the healthier cereal. But because of the addition of vitamins (fortification), it will likely not be able to retain or acquire a “natural” label due to that.
How might we determine whether foods labeled “natural” comply with any criteria for bearing the claim?
And this is the crux of the entire argument. If there is a decision that requires natural to be defined in such as way as to required food manufacturers and processors to comply with that definition, then we require more than just redefining a word. It requires a significant effort to redefine the word, share the regulations, and promote the new definition among all vendors and purchasers.
Which leads all of this to become little more than a marketing tool and it uses to the power of the US government to promote some vendors over others. Some food product vendors will simply be unable to comply with any regulations about natural, almost no matter what the definition is. I would think things like shelf stable, ready to eat meals could not possibly be considered “natural” by any common definition of natural. But there are products that are currently labeled as natural which may not be able to some requirements.
In effect, the US government would be picking and choosing some products that get to have the “natural” label, while other products may not have that label, which will promote the idea that they are “unnatural” or “unhealthy”. This is especially true if the natural definition considers certain compounds that are extremely common, for example, salt, sodium bicarbonate, acetic acid, ascorbic acid, etc.
Instead of defining “natural” and restricting use of the word to a specific range of criteria, I would suggest that the FDA and USDA promote the idea that natural is a marketing ploy and has no effect on the nutritional value or healthiness of the food.
