"Natural flavor" has an FDA definition: a flavoring extracted or made from a spice, fruit, vegetable, herb, root, leaf, bark, yeast, meat, seafood, eggs or dairy, by pressing, distilling, roasting, heating or fermenting, used for flavor rather than nutrition. In the ingredient list it can be declared as "natural flavor". The harder part is the front of the label. Once you name a flavor there, "raspberry" on a kombucha, FDA's rules decide the wording, set at least half the height of the food's name. Enough real raspberry to give the flavor: call it raspberry kombucha. A little raspberry plus a natural flavor made from raspberries: "natural raspberry flavored" or "raspberry flavored". Real raspberry plus other natural flavors backing it up: "with other natural flavor". And a "natural" flavor that isn't made from the named fruit can't make the fruit look natural: the food is labeled with the flavor of what it's made from, or as artificially flavored. In the example below, a Portland kombucha maker names five flavors.
The short version
- Natural flavor: extracted or made from a plant or animal source, used for flavor.
- In the ingredient list, it can be declared as "natural flavor".
- Name a flavor on the front, and its wording is set by the rules, at least half the food's name height.
- Enough of the real fruit: the plain name, such as raspberry kombucha.
- A little fruit plus natural flavor from that fruit: natural raspberry flavored, or raspberry flavored.
- A natural flavor not made from the named fruit: artificially flavored, or name its real source.
- TaroStack keeps each flavor as its own recipe, so a batch's flavorings are on record. More below.
How to name the flavor
| What's in it | Front of the label |
|---|---|
| Enough of the real fruit to give the flavor | Raspberry kombucha |
| Not enough fruit, plus natural flavor from that fruit | Natural raspberry flavored kombucha, or raspberry flavored kombucha |
| Real fruit plus other natural flavor that backs it up | Raspberry kombucha with other natural flavor |
| Natural flavor not made from the named fruit | Artificially flavored, or named for the flavor's real source |
| Any artificial flavor for it | Artificially flavored raspberry, or artificial raspberry |
How ingredients are listed is in ingredient list order, and "all natural" claims in all natural label claim.
The rules
| Rule | Where |
|---|---|
| What natural flavor is | An extract or product of roasting, heating or fermenting, from plant or animal sources, whose function is flavor (21 CFR 101.22(a)(3)) |
| Naming the flavor | The characterizing flavor accompanies the food's name at least half its letter height; flavored, natural flavored, with other natural flavor, or artificially flavored, by source (101.22(i)) |
| Not from the named fruit | Labeled with the flavor of the source it's made from, or as artificially flavored (101.22(i)(1)(ii)) |
This is general information, not legal advice.
An example: five kombuchas
Brightwater Ferments, the made-up kombucha, kimchi and sauerkraut maker in Portland, Oregon, I use in these examples, named its kombucha flavors for a new label run:
| Kombucha | What flavors it | Front of the label | Ingredient list |
|---|---|---|---|
| Ginger | Fresh ginger juice, plenty of it | Ginger kombucha | Ginger juice |
| Raspberry | A little raspberry juice, natural raspberry flavor | Raspberry flavored kombucha | Natural flavor |
| Raspberry lime | Raspberry and lime juice, natural flavors that back them up | Raspberry lime kombucha with other natural flavor | Natural flavor |
| Mango | A natural flavor made from other fruits, no mango | Not "mango": artificially flavored, or reformulated | Natural flavor |
| Cherry cola | An artificial cherry flavor | Artificially flavored cherry cola kombucha | Artificial flavor |
The mango was the surprise: its supplier's "natural mango type flavor" is made from other fruits, so the kombucha couldn't be sold as natural mango. Brightwater switched to a mango purée plus a natural flavor made from mango, which made it "mango flavored kombucha". The flavor supplier's spec sheet, saying what each flavor is made from, now goes in the file with every flavor bought. What a bottle costs is in kombucha business plan.
Get the helper
Download the flavor naming helper. One sheet: each product's named flavor, whether there's enough of the real thing, whether a natural flavor from it is used, whether other natural flavors back it up, and whether any artificial flavor is used; the front-of-label naming and the ingredient-list wording fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The naming is right for the flavor on today's spec sheet. When a flavor supplier changes, or a batch uses the old flavor by mistake, the label's wording can quietly stop matching what's in the bottle.
How TaroStack does it
TaroStack keeps each flavor as its own recipe, so a batch's flavorings are on record.
Recipes by weight. Each kombucha flavor is its own recipe, with its juice and flavoring by weight or volume.
Receiving by supplier and lot. Each flavoring is received from its supplier with its lot, so a change of supplier is on record.
Batches by lot. Each batch records which flavoring lot it used, so a question about one bottle leads to the flavor and its supplier.
| The job | Notebook | In TaroStack |
|---|---|---|
| Which flavoring went into a batch | Remembered | Batches by lot |
| A new flavor supplier | Noticed later | Each delivery by supplier |
| Which recipe a batch followed | A tag on the tank | Each batch from its recipe |
Recipes, batches and lots 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.