Update on FDA “Natural” Food Labeling

Currently the FDA does not have a rule defining “Natural” food labeling. However, as we previously posted, the FDA has sought public comments on how the Agency should define the term “natural” and regulate its use in food labeling. The FDA engaged the public’s input after receiving two Citizen Petitions requesting FDA take action on establishing a formal definition of the term “natural” food labeling and one requesting FDA to prohibit the use of the term “natural” on food labels. Based on a review of comments received by the FDA, it appears that public sentiment agrees: “Natural” is prone to being misleading.

But what does the FDA think about “natural” food labeling, and what is legally required to appear on food labels?

While FDA regulations currently do not define “natural” for use in food labeling, the Agency has maintained a longstanding policy concerning the use of “natural” food labeling. FDA’s nonbinding guidance on this subject defines “natural” as “nothing artificial or synthetic (including all color additives regardless of source) has been included in or has been added to, food that would not normally be expected to be in the food.” Although this policy touches on the qualitative aspects of food, this policy does not address production methods and food processing or manufacturing methods. Further, the FDA also does not presently consider in its non-binding guidance whether the term “natural” should describe any nutritional or another health benefit derived from such foods.

Currently, importers and marketers of FDA regulated foods are open to use “natural” claims in labeling so long as the foods meet this minimal standard. However, based on public comments urging FDA to define “natural” for use in food labeling, changes may be on the horizon.

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