The American Herbal Products Association (AHPA) submitted comments to the U.S. Food and Drug Administration (FDA) encouraging the agency to establish, through rulemaking, a regulatory definition for the term “natural” (and possibly other terms, such as “100 percent natural” and “made with natural [named ingredient(s)]”) for the labeling of human food products, and other products regulated by FDA such as animal foods, cosmetics and botanical drugs.
“Consumers seek such a designation on foods and other products and it is important to some consumers’ purchasing and consumption decisions,” said AHPA President Michael McGuffin. “Creating a regulatory definition of natural and related terms for product labels will help ensure that consumers are not misled by inconsistent or inaccurate uses of this term.”
AHPA also suggested that the term (or terms) be allowed on labeling not only on raw agricultural products but also on multi-ingredient and processed foods. AHPA’s comments include ideas about how the term natural should be defined and how FDA should enforce any resulting rule.
“Natural processed food must be derived only from natural ingredients and must be processed in a manner that retains the natural quality of the starting ingredients,” McGuffin said. “Any food manufacturing process that is a traditional food preparation process should be recognized as maintaining the natural quality of the ingredients used to make a multi-ingredient or traditionally processed food.”
AHPA has also expressed support for FDA’s cooperation with USDA (U.S. Department of Agriculture) to ensure consistent use of “natural” labeling of all foods, irrespective of agency jurisdiction, and has also recommended that current regulatory definitions of “natural flavor and natural flavoring” be retained.
AHPA isn’t alone in their quest for a definition for “natural.” The Natural Products Association (NPA) has also submitted comments asking that the FDA define natural. NPA’s comments can be found here.
“Natural should mean natural, which in our general view is no chemicals, no additives, and only should involve minimal processing,” said Daniel Fabricant, PhD, CEO and executive director of NPA. “A national standard is the best, most cost-effective and least-confusing way to deliver on this commitment for American consumers. To have hundreds of different state and local requirements would be counterproductive and expensive. NPA welcomes this opportunity to submit comments to FDA and looks forward to reviewing the final guidance from the Agency when it becomes available.”
“FDA should create a regulatory definition of natural that is reasonably consistent with consumers’ understanding of the term, as shown through market research,” McGuffin added.
AHPA’s comments also urge FDA to prohibit use of the term natural on labeling of raw agricultural commodities from crops produced with genetic engineering (GE), include in the definition of “natural” those ingredients derived from crops resulting from traditional hybridization between closely related taxa.
On November 12, 2015, FDA issued a Federal Register notice soliciting information and comments on use of the term natural in the context of food labeling. FDA explained in the November 12 Notice that it was taking this action in part because it had received three citizen petitions asking it to define the term for use in food labeling and one citizen petition asking for the term to be prohibited on food labels. The November 12 Notice also referenced litigation between private parties in some Federal courts over use of the term and reported that FDA is working with the USDA Agricultural Marketing Service and Food Safety and Inspection Service to also examine the use of the term natural in meat, poultry, and egg products, and is considering areas for coordination between FDA and USDA.