It’s Simply ‘Natural’

With the increase in ‘clean label’ products showcasing innovation in conjunction with sustainability, the use of words such as ‘pure’ and ‘natural’ to set products apart from the rest is becoming more common. Although health claims about food products are prohibited by the Regulations Relating to Labelling and Advertising of Foodstuffs (R. 146/2010, as amended), they do make provision for the use of certain terms, such as ‘natural’ – in Guideline 7, which makes reference to the Food Standards Authority (FSA) of the United Kingdom (UK) Criteria for the use of the terms ‘fresh’, ‘pure’, ‘natural’, etc. in food labelling. This begs the question: When can I say ‘Natural’, and why?

As the onus is on the manufacturer to ensure that claims on food products and the advertising thereof are not misleading to the consumer, it is important to know when it is appropriate to use the claim ‘natural’.

According to the FSA document, “‘Natural’ means essentially that the product is comprised of natural ingredients, i.e. ingredients produced by nature, not the work of man or interfered with by man.” The document states further that: “It is misleading to use the term to describe foods or ingredients that employ chemicals to change their composition or comprise the products of new technologies, including additives and flavourings that are the product of the chemical industry or extracted by chemical processes.”

Simply put, this means that a product is only considered to comply with the ‘natural’ claim if it is a single food, to which nothing has been added, and it has only been subject to processing (for example fermentation, pasteurisation or freezing) that would allow the food to become suitable for human consumption.

To illustrate this further: coconut water that is extracted from actual coconuts and then pasteurised is an example of a product that could be called ‘Natural Coconut Water’; however, a coconut-flavoured drink could not be referred to as ‘natural’ – even in a case where the flavouring is derived from raw coconut, as this process would employ chemicals as well as ‘the work of man’.

As a manufacturer, one must be mindful of the use of so-called ‘poetic licence’; claims such as ‘naturally derived’, ‘sourced from nature’ and ‘nature’s way’ would all be considered confusing and/or ambiguous.

FACTS has over 15 years of regulatory experience in the food industry; for advice on the use of ‘natural’ and related claims, or for training to better understand the use of such claims, please contact us.

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