Think of that busy mom in a grocery store, standing in front of a wall of granola bars. How does she choose which one to buy? Does she pick the all-natural chocolate peanut butter kind or the not-all-natural chocolate peanut butter kind? Does she believe that products labeled “natural” actually are natural? What does “natural” even mean? What do YOU think “natural” should mean?
On Nov. 12, 2015, — after years of consumer litigation, consumer petitions, and consumer pressure — the U.S. Food and Drug Administration (FDA) issued a request for information and comments on the use of the term “natural” to try and address these and other grocery-store-food-label-inducing-decision-paralysis questions that consumers (naturally) have these days.
The FDA wants to know whether it should even attempt to define the term in a regulation, and, if it does propose a regulatory definition, how the term should be defined. Should “natural”-labeled products be allowed to contain genetically modified ingredients or high fructose corn syrup? Can pesticides be used on “natural” food? Should “natural” be allowed only on unprocessed foods? What does “unprocessed” mean? Should the FDA prohibit the use of the term from food labels entirely? To what degree do consumers confuse “natural” with “healthy” and/or “organic” (both of which have regulatory definitions)? Should “natural” foods be required to have some nutritional benefit?
The FDA attempted to define natural once before, in 1991. In the end, despite receiving numerous comments,
[n]one of the comments provided FDA with a specific direction to follow for developing a definition regarding the use of the term ‘natural.’
Instead of creating a regulatory definition, the FDA continued to rely on its longstanding policy to not restrict use of the term except for added color, synthetic substances, and flavors, and to define “natural” to mean “that nothing artificial or synthetic (including colors regardless of source) is included in, or has been added to, the product that would not normally be expected to be there.”
It was difficult to define “natural” then, and I cannot imagine it will be easier now. For one thing, the national conversation around food issues has increased tremendously since 1991. Consumers are more aware of food issues and are largely more food literate than they were in 1991; at the least, consumers today are paying attention to terms like “natural,” “healthy,” and “organic.” The food industry, in turn, recognized these consumer trends and responded with new labeling and marketing. The result is a marketplace where “natural” food products are seemingly ubiquitous. Natural cookies, natural granola bars, natural cereal, natural chips, natural soup, natural yogurt, natural juice … the list goes on. These foods are labeled 100% natural, made with all-natural ingredients, or are all natural. Do consumers believe that these products do not contain anything that “would not normally be expected to be there”?
Wherever you fall on the issue, the reality is that consumers are confused and everyone wants some guidance on how to use the term “natural” on foods. Although the FDA will not have an easier time proposing a regulatory definition, they have at least provided the public with an opportunity to weigh in on this important issue.
If you are a food or beverage company or restaurant that uses the term “natural” in your product labels, labeling, or menus, you should submit a comment. If you are a consumer with an opinion about natural or if you are confused about the term, you should submit a comment. The FDA needs as many points of view as possible. And, if their past practice is any indication, it could be another twenty-four years before FDA revisits the issue. Better get those comments in now.
The comment period closes Feb. 10, 2016. Find out more about the request for information and how to submit comments here.