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The Emptiness of "100% Natural"

03/26/08, by Kate Hopkins Email 1040 views • Categories: Labeling

Parke, over at US Food Policy, reminds us once again that the word "Natural" should be regarded with great skepticism when found on food labels.

Part of my real-world job involves parsing words and phrases, interpreting meaning in poorly worded passages, and generally understanding government regulations. So when I read the USDA's definition of natural for meat and poultry...

A product containing no artificial ingredient or added color and is only minimally processed (a process which does not fundamentally alter the raw product) may be labeled natural. The label must explain the use of the term natural (such as - no added colorings or artificial ingredients; minimally processed.)

Writing regulations and requirements is not like the writing you and I do in everyday life. Everything must be unambiguous, consistent, and verifiable. In parsing the above, I find (and others have found) several flaws with the above, specifically in the area of ambiguity and verifiability. For example:

  • No artificial ingredient - How is "artificial" defined?
  • Minimally processed - What defines "Minimally"?
  • Does not fundamentally alter the raw product - What is the criteria for any product to not be "fundamentally altered"?

The answer to the first issue is likely found in a different set of regulations, where each ingredient is identified as artificial or not. The other two issues are more severe. For only being one sentence, having three issues shows poor oversight by the USDA. Adverbs and adjectives are often indications of poor regulations, unless they are defined as well. Without clarification of these terms, it leaves the regulation open for interpretation and abuse - which is precisely what has happened.

The simple answer is to look upon the phrase "natural" with great suspicion, unless a company puts some effort in communicating answers to the three issues listed above. The problem with this is that it is counter-intuitive for the purpose of the "natural" label.


Comments, Pingbacks:

Comment from: ntsc [Visitor] Email · http://blog.charcuteire,com
artificial - those products which include a transuranic element, all other elements being naturally occuring.

Minamally processed - only processed enought to get the product to the point people will buy it.

Does not fundamentally alter the raw product - no portion of the product has been transmuted in production.

See it is simple.
PermalinkPermalink 03/26/08 @ 11:29
Comment from: Robert [Visitor] Email · http://alforno.blogspot.com
Yes, the "all natural" label is all but meaningless today. It's sort of along the lines of chicken producers promoting their chickens as being "hormone free" when, actually, ALL chickens sold in the us are hormone free, since (as the fine print on the label says) federal regulations prohibit the use of hormones in chickens.
PermalinkPermalink 03/27/08 @ 03:53
Comment from: Beany [Visitor] Email
That's not the full definition; it's just a summary. The original FSIS Policy Memo 055 (1982) apparently said:

"The term "natural" may be used on labeling for meat products and poultry products,
provided the applicant for such labeling demonstrates that: l) The product does not
contain any artificial flavor or flavoring, coloring ingredient, or chemical preservative
(as defined in 21 CFR 101.22), or any other artificial or synthetic ingredient; and 2) the
product and its ingredients are not more than minimally processed.

For the purposes of
this memorandum, minimal processing may include: (a) those traditional processes used
to make food edible or preserve it or make it safe for human consumption, e.g., smoking,
roasting, freezing, drying, and fermenting; or (b) those physical processes which do not
fundamentally alter the raw product and/or which only separate a whole, intact food into
component parts, e.g., grinding meat, separating eggs into albumen and yolk, and
pressing fruits to produce juices…

All products claiming to be natural or a natural food should be accompanied by a brief
statement which explains what is meant by the term natural, i.e., that the product is a
natural food because it contains no artificial ingredients and is only minimally
processed. This statement should appear directly beneath or beside all natural claims or,
if elsewhere on the principal display panel, an asterisk should be used to tie the
explanation to the claim. The decision to approve or deny the use of a natural claim may
be affected by the specific context in which the claim is made. For example, claims
indicating that a product is a natural food, e.g., "Natural chili" or "chili - a natural
product" would be unacceptable for a product containing beet powder which artificially
colors the finished product. However, "all natural ingredients" might be an acceptable
claim for such a product"

It's been revised since for clarification, and I've tried to find the new version on the FSIS website, but haven't been able to.
PermalinkPermalink 03/27/08 @ 07:13

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