6 min read

Natural Food Label

Quick answer

Natural food label claims have no formal FDA definition. FDA has a long-standing policy instead: "natural" means nothing artificial or synthetic, including any color additive from any source, has been included in or added to a food that would not normally be expected in it. The policy does not cover farming methods or processing like pasteurization, and it says nothing about health benefits. No certification or approval exists for "natural" or "all natural"; the claim just has to be truthful and not misleading.

Natural food label on a jar of strawberry jam: "All natural" on the front and a short ingredient list of strawberries, sugar, lemon juice and pectin on the back
A short, plain ingredient list is what backs up the word
01

What FDA says "natural" means

FDA, Use of the Term "Natural" on Food Labeling"The FDA has considered the term "natural" to mean that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food."

That sentence is a policy, not a regulation. FDA says so itself: it has never done rulemaking to set a formal definition. There is no list of approved ingredients, no threshold and no FDA logo for natural.

FDA, Use of the Term "Natural" on Food Labeling"Although the FDA has not engaged in rulemaking to establish a formal definition for the term "natural," we do have a longstanding policy concerning the use of "natural" in human food labeling."
02

What the natural policy leaves out

FDA spells out three things its policy was never meant to settle. "Natural" says nothing about any of them:

TopicCovered by the natural policy?
Farming methods, such as pesticide useNo
Processing, such as heat treatment, pasteurization or irradiationNot explicitly
Nutrition or other health benefitsNo
FDA, Use of the Term "Natural" on Food Labeling"However, this policy was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation."

FDA also notes that federal courts have asked it whether foods with genetically engineered ingredients or high fructose corn syrup may be labeled "natural". Its page asked the public for input on whether and how to define the term, and gives no answer to those questions. So for both, the honest status is: undecided by FDA.

03

All natural food label: an ingredient-by-ingredient check

Read your full ingredient list, sub-ingredients included, and ask these questions. By the wording of FDA's policy, each yes works against a natural claim:

QuestionWhere it shows upRule behind it
Is any color added?"Color added", "colored with beet juice", "Red 40": the policy counts all color additives, from any source21 CFR 101.22(k)
Is there an artificial flavor?Listed as "artificial flavor": a flavor not derived from a spice, fruit, vegetable, herb, meat, dairy or similar source21 CFR 101.22(a)(1), (h)(1)
Is there a chemical preservative?Declared with its function, like "potassium sorbate (preservative)"21 CFR 101.22(a)(5), (j)
Is anything synthetic that shoppers wouldn't expect in this food?Store-bought parts like syrups, coatings and mixes, once you open them up into their own ingredientsFDA natural policy

Our tool helps with the reading part: it writes the ingredient statement heaviest first and puts each store-bought ingredient's own ingredients in parentheses, so a color or preservative inside a mix doesn't stay hidden. It does not judge whether a natural claim fits.

Build your ingredient list: Ingredient label maker →
04

"Natural flavor" in the ingredient list is a different thing

"Natural flavor" has a real regulatory definition, unlike "natural" on the front. It is an extract, essential oil, distillate or similar product made from a spice, fruit, vegetable, herb, meat, seafood, dairy or another listed source, used for flavor rather than nutrition. A food may list "natural flavor" and still not meet FDA's natural policy because of a color or preservative elsewhere in the list.

  • In the ingredient list, natural flavor may be declared simply as "natural flavor"
  • A protein hydrolysate used for flavor may not hide behind "natural flavor"; it needs its own name
  • When the named flavor comes from a natural flavor rather than enough of the real fruit, the name changes: "natural strawberry flavored shortcake" or "strawberry flavored shortcake"
21 CFR 101.22(a)(3), (h)(1), (h)(7), (i)(1)(i)The definition of natural flavor, how it is declared, protein hydrolysates, and characterizing flavor names.
05

"Natural" and "no artificial colors" are separate claims

FDA now says it does not intend to take action against "no artificial colors" style claims on foods that contain none of the certified colors listed in 21 CFR part 74, even if colors from natural sources are used. That letter is about the "no artificial colors" claim only. It does not mention "natural", and FDA's natural policy still reads "all color additives regardless of source".

ClaimFood colored with beet juice, no certified colors
"No artificial colors"Covered by FDA's enforcement discretion letter
"Natural" or "all natural"A color additive is in the food, which the natural policy counts against the claim
FDA, Letter to the Food Industry on "No Artificial Colors" Labeling Claims"Made without artificial food colors/colorings", "No artificial color/colors/coloring" and "No added artificial color/colors/coloring", for foods without any colors listed in 21 CFR part 74.
06

Natural, organic and non-GMO compared

NaturalOrganicNon-GMO
Who sets the rulesFDA policy, no regulationUSDA National Organic Program, 7 CFR part 205FDA guidance for absence claims; USDA rules for bioengineered disclosure
CertificationNone existsRequired, except for operations exempt under 7 CFR 205.101Optional, through private programs; USDA does not certify it
Covers farming methodsNoYesOnly whether bioengineering was used
FDA, Use of the Term "Natural" on Food Labeling · 7 CFR 205.100, 205.101 · FDA, Voluntary Labeling Indicating Whether Foods Have or Have Not Been Derived from Genetically Engineered Plants · USDA AMS, BE FAQFDA's natural policy, who must be certified organic, FDA's guidance on voluntary non-GE claims, and USDA's answer that it does not certify foods as bioengineered or not.
Organic Food Label Requirements (USDA) →Non GMO Label →
07

Natural claim checklist

0 of 5 checkedSaved on this device
08

Official sources

FDA: Use of the Term "Natural" on Food Labeling (fda.gov) →21 CFR 101.22, spices, flavorings, colorings and chemical preservatives (ecfr.gov) →FDA: Letter to the Food Industry on "No Artificial Colors" Labeling Claims (fda.gov) →
Questions

Questions

No formal one. FDA has never set it by regulation. Its policy treats "natural" as meaning nothing artificial or synthetic, including any color additive, has been added that wouldn't normally be expected in the food.

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