IFT Comments on ‘Natural’ Labeling

In response to a few citizens’ petitions filed to the U.S. Food and Drug Administration (FDA) to define or prohibit the use of the term natural and litigations between private parties, in December 2015, the FDA issued a proposed rule for public comments on “Use of the term natural in the labeling of human food products.” This article provides excerpts of IFT’s comments that were submitted to FDA. Complete comments are available here.

The label on food packages is valuable to consumers if it provides science-based information that helps them in making informed purchasing decisions. To reduce or prevent consumer confusion and misinterpretation of the term “natural,” the FDA should consider clearly defining or prohibiting the use of the term natural on food labels. Should the agency decide to define the term natural for use on food labels, then IFT recommends:

• Careful consideration of the roles (e.g., food safety, preservation, nutritional quality) of various processing technologies.

The purpose of food processing has evolved primarily from preservation and safety to addressing quality, availability, convenience, nutrition, health and wellness, sustainability, and post-harvest losses amongst others. Hence, limiting the term natural to a list of “traditional processes” similar to those in the U.S. Dept. of Agriculture/Food Safety and Inspection Services policy will create multiple anomalies and should be considered with caution. Methods of food manufacturing are only one aspect of delivering food to consumers, and are inextricably linked to methods for growing, producing, harvesting, storing, processing, packaging, warehousing, and distributing foods. Any rationale to include or exclude food processing methods in the definition of natural must consider the basis for using the methods and the steps in the chain preceding and following the delivery of safe, nutritious, affordable, and accessible foods. The degree of complexity that a definition would require to include food manufacturing processes as a component would make applying it almost insurmountable. Further, with the rate of advances in food processing methods, and ever-changing consumer demands and behaviors, applying a food processing component in the definition would soon be outdated.

• Educate consumers on the definition of the term natural and standards or guidelines, how specific foods and ingredients with or without the natural label fit into their dietary patterns, and the meaning of the absence of natural label on foods.

The demand for foods and beverages labeled natural is increasing. The International Food Information Council (IFIC) reported a slight increase in the number of consumers (40% in 2015 vs. 37% in 2014) purchasing foods and beverages advertised as natural on the label. However, the current policy related to the use of the term natural is vague and can lead consumers to make judgments that are not scientifically accurate. For example, the 2015 Consumer Reports’ National Research Center survey reported that consumers think natural labeling on food means that no toxic pesticides (63%), no artificial materials or chemicals (62%), no artificial ingredients or colors (61%), and no GMOs (60%) were used; and that the natural claim is verified (45%), whereas these may not be true.

Consumers are skeptical of the term natural on a label, however, they still look for and find value in it. For example, IFIC reported that 63% of consumers think sugars that are naturally found in food and beverages are more healthful than other sugars. Another survey showed that about two-thirds of consumers believe “when I see products labeled as ‘all natural,’ I think it’s healthy.” While this statement may or may not be accurate, it is important to acknowledge that consumers believe that natural and healthy are largely linked.

• Careful consideration of whether modern genetic modification techniques should be included or excluded in the definition of natural.

The transfer and exchange of genetic material occurs naturally. Recently, gene technology has enabled the transfer of specifically targeted traits from one organism to another, dramatically reducing their random nature, the time needed to express the improved trait, and the ability to identify a plant or animal with the desirable traits. Foods and beverages produced through newer technologies have not been found to differ in safety from those produced using older methods.

IFT also recommended that the agency:

• Consider setting standards or guidelines in addition to defining the term natural.

• Seek harmonization of the definition and standards or guidelines across all federal agencies.

• Provide a brief explanatory label descriptor to accompany the term, regarding what is meant by the use of the term natural.

IFT stated that “It is important that any rulemaking be science-based and clarifying, and not perpetuate inaccurate consumer perceptions” and that “use of the term ‘natural’ should not mislead consumers into thinking that these foods are superior when in reality they are comparable in health and safety to other foods not bearing the term ‘natural.’”

IFT appreciates contributions from Christine Bruhn, Robert Gravani, Robert Post, John Ruff, and Marcia Walker in preparing these comments.

Farida Mohamedshah, MS, CNS, is director, Food, Health and Nutrition, IFT, Washington, DC ([email protected]).