FDA has never defined "natural" in a regulation. What it has is a longstanding policy: it considers "natural" to mean that nothing artificial or synthetic has been included in or added to a food that wouldn't normally be expected in it, including all color additives, whatever their source. So a snack colored with beet juice doesn't fit the policy, even though beets are a vegetable, and neither does one flavored with synthetic vanillin. The policy doesn't cover how the food was grown or processed, and says nothing about whether it's healthier. Meat and poultry follow USDA's own rule: no artificial ingredient or added color, only minimally processed, and a statement on the label saying what "natural" means. "All natural" is held to the same policy; "all" only promises more. In the example below, a popcorn maker sorts six products for a gift shop that wants the claim. Below are the rules, the flavors and colors, the example, and a free checker.
The short version
- FDA has a policy on "natural", not a regulation.
- Natural, to FDA: nothing artificial or synthetic added that wouldn't normally be in the food.
- Every color additive counts against it, including colors from fruit, vegetables and spices.
- Artificial flavors count against it; natural flavors, as 21 CFR 101.22 defines them, don't.
- The policy doesn't address farming methods such as pesticides, or processing such as pasteurization.
- Meat and poultry: no artificial ingredient or added color, minimally processed, with a statement explaining the term.
- A product that holds several items can say "natural" only if every item fits.
- TaroStack keeps each recipe's ingredients by version, so a changed ingredient shows a changed recipe. More below.
The rules
| Who | What "natural" means |
|---|---|
| FDA, for most foods | Nothing artificial or synthetic, including all color additives regardless of source, included in or added to a food that wouldn't normally be expected in it |
| FDA, not covered | Production methods such as pesticides; processing such as thermal technologies, pasteurization or irradiation; nutrition or health benefits |
| USDA, meat and poultry | No artificial ingredient or added color, and only minimally processed, meaning not fundamentally altered |
| USDA, on the label | A statement explaining the term, such as "no artificial ingredients; minimally processed" |
FDA's policy is on its natural labeling page, where it notes it asked for public comment on defining the word and that courts in private lawsuits have asked it for answers. USDA's meat and poultry definition is in its labeling terms. This is general information, not legal advice.
Flavors, colors and preservatives
21 CFR 101.22 sets the terms the policy leans on:
| Term | What it means | Against the policy? |
|---|---|---|
| Natural flavor | An oil, oleoresin, extract, distillate or similar whose flavor comes from a spice, fruit, vegetable, herb, meat, seafood, eggs, dairy or their fermentation products | No |
| Artificial flavor | A flavoring not derived from those sources | Yes |
| Artificial color | Any color additive | Yes, whatever the source |
| Chemical preservative | A chemical added to slow spoilage, other than salt, sugar, vinegar, spices, wood smoke and a few others | A synthetic one, yes |
A spice that also colors, such as paprika, turmeric or saffron, is declared as "spice and coloring" unless it's named. How the ingredient list itself is written is in food labeling requirements for small business.
An example: a popcorn maker and a gift shop
Copper Kettle Popcorn, the made-up popcorn maker in Columbus, Ohio, I use in these examples, sells gift tins to a shop that asked for "all natural" on the label:
| Product | What matters | Fits FDA's policy? |
|---|---|---|
| Kettle corn | Popcorn, cane sugar, sunflower oil, salt | Yes |
| Caramel corn | Brown sugar, butter, pure vanilla extract | Yes: vanilla extract is a natural flavor |
| Caramel corn with vanillin | Synthetic vanillin | No: an artificial flavor |
| Cheddar corn | Cheese powder colored with annatto | No: annatto is a color additive |
| Cherry corn | Beet juice concentrate for color | No: a color additive, though it's from beets |
| Blue raspberry corn | Blue 1 and artificial flavor | No |
The three-flavor tin held kettle, caramel and cheddar, so the cheddar's annatto ruled the tin out. Copper Kettle switched to a white cheddar powder without annatto, asked the supplier for its specification sheet to confirm, and kept "all natural" off the cherry and blue raspberry bags. How the products' costs work is in popcorn business plan, and how a supplier's specifications are kept in approved supplier list.
Get the checker
Download the natural claim checker. Two sheets: ingredients, each with its role and whether it's artificial or synthetic or a color additive, with anything against the policy in red; and by product, each product's count of ingredients against the policy and where it stands. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
A "natural" claim is true for one recipe with one set of ingredients. A supplier changes its cheese powder, a new flavor goes into the tin, and the claim on a printed label can stop being true without anyone noticing.
How TaroStack does it
TaroStack keeps each recipe's ingredients by version, so a changed ingredient shows up as a changed recipe.
Recipes by version. The cheddar corn recipe names the white cheddar powder; switching powders is a new version on a date, so you know which labels were printed under which recipe.
Supplier lots. Receiving records each lot of cheese powder with its supplier, and batch records note which lots were consumed, automatically.
Where it went. The gift shop's orders record the lots in each tin, so one recall report shows every customer a lot reached if a supplier's ingredient turns out not to be what its sheet said.
| The job | Notebook | In TaroStack |
|---|---|---|
| Which powder a recipe uses | Remembered | A recipe version on a date |
| Which lot went into a batch | Not recorded | Recorded on the batch |
| Which customers got a batch | Invoice by invoice | One recall report |
Recipes, batches, lots and orders are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.