We all have cupboards full of products claiming to be “natural,” “all natural” or “100% natural,” but what do these terms really mean? The Food and Drug Administration (FDA) recently issued a request for public comment on why a binding and comprehensive definition of the term “natural” is necessary and what that definition should be. The FDA is seeking public comment because it received citizen petitions asking both that the agency define the term “natural” and that the term be prohibited. Additionally, there has been litigation over the issue of whether foods labelled as “natural” can contain genetically engineered ingredients or high fructose corn syrup.
In 1993, the FDA issued a non-binding guidance document indicating it considered the term “natural” to mean that nothing not normally expected to be in a food, artificial or synthetic(including all color additives regardless of source) had been included or added to that food. According to the FDA, the term “natural” was not intended to address food production methods, such as the use of genetic engineering or other forms of genetic modification, pesticides, or specific animal husbandry practices. 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.
Under section 403(a)(1) of the Federal Food, Drug, and Cosmetic Act (the FD&C Act) (21 U.S.C. 343(a)(1)), a food shall be deemed misbranded if its labeling is false or misleading in any way. The lack of clarity in the definition of “natural” has forced many food manufacturers to guess as to what qualifies as a “natural” product and then to face legal claims that they have misbranded food as “natural.”
Specifically, the FDA wants to hear from the public about:
- Whether it is appropriate to define the term “natural,”
· - If so, how the agency should define “natural,” and
·- How the agency should determine appropriate use of the term on food labels.
An example of the type of input on this topic received by the FDA is from the Grocery Manufacturers Association, which requested that FDA find it is neither false nor misleading to label a food as “natural” or similar terms solely because the food is or contains a food derived from biotechnology. By way of contrast, the Consumers Union has requested that FDA prohibit use of the term “natural” on food labels altogether because of the difference between FDA's current policy for use of the term “natural” and what people think the “natural” label should mean.
So this holiday season, as you make conversation with family members while avoiding the typical taboos of religion and politics, why not ask Aunt Ida what she thinks the term “natural” means and then send her thoughts and yours to the FDA to help them resolve this labeling juggernaut. The FDA will be accepting public comments until February 10, 2016. Details on how to submit your comments can be found at: