When Can a Food Product Be Labeled as “Natural”?

If you’re creating a label for your food product, you may be inclined to include the word “natural” on it. But think twice before you do, as many food companies have found themselves at the wrong end of a lawsuit for stating "natural" on their label.

“Natural” is not synonymous with “organic.” The Food and Drug Administration (FDA) has yet to define “natural”, but any food product labeled as organic must comply with the requirements of the Organic Foods Production Act of 1990, which is administered by the U.S. Department of Agriculture. In short, this means that organic ingredients must be grown on land free of certain pesticides, and for meat products, animals cannot be given growth hormones. Many consumers do not know there’s a difference between organic and natural, but legislators, food lawyers and the courts do. Using “organic” when not appropriate can get you into trouble.

What does “natural” mean on a food label?

Businesses are routinely face lawsuits for making “natural” claims. In 2016, Whole Foods agreed to settle two class-action lawsuits about “all natural” bread, and in October 2018 a suit was announced against the parent company of LaCroix beverages stating that claims of “all natural” and “100% natural” associated with their beverages were false and misleading.

Why so much controversy over what constitutes “natural”? Well, the fact is that certain ingredients may in some cases be healthful and in others poisonous, sometimes derived from natural sources or synthetic sources. For example, the LaCroix suit charges that the drink contains linalool, which is used in cockroach insecticide. But linalool is also found in many plants and is frequently used in flavoring. Citric acid, a common preservative, can be chemically manufactured in a lab, but it can also be extracted from citrus plants. It’s the same chemical compound either way, but in one instance it is considered “natural” and in the other it’s not. 

The FDA was actually tasked to define “natural” by the Food Safety and Modernization Act of 2011, but it has not yet provided a definition, leaving food manufacturers and importers in limbo. Nevertheless, the FDA has issued guidelines for the use of “natural” which includes “nothing artificial or synthetic is included in, or has been added to, the product that would not be expected to be there.” Also, “natural” products should have no genetically modified ingredients (i.e., non-GMO).

Include “natural” on your label?

Should you be making a “natural” claim on your food label?

Of course, it depends on your product and ingredients. Just because you think it’s natural, that doesn’t mean it really is–at least not in a legal sense. If you plan to make an “all natural” claim, you must make sure you have a real understanding of all the ingredients in the product and their sources.

Maybe your product uses vanilla extract, for example. Where does that vanilla extract come from? How is it manufactured? Is it certified organic, completely synthetic or something else?

If you decide you do want to make an “all natural” claim, we’d recommend enlisting the services of a regulatory expert, like US Imports, before doing so. 

Check out US Imports' claims review services to learn more.