Method of production claims on food labels
"Nature", "natural", "Mother Nature", "Nature's Way" are terms often misused on labels and in advertisements.
Labels and advertisements should not convey the impression that "Nature" has, by some miraculous process, made some foods nutritionally superior to others or has engineered some foods specially to take care of human needs. Some consumers may consider foods described as "natural" of greater worth than foods not so described.
A food or ingredient of a food that is represented as natural is expected:
- not to contain, or to ever have contained, an added vitamin, mineral nutrient, artificial flavouring agent or food additive
- not to have any constituent or fraction thereof removed or significantly changed, except the removal of water. For example: the removal of caffeine
- not to have been submitted to processes that have significantly altered their original physical, chemical or biological state (i.e. maximum processes). See Annex 1 – Minimum processes and Annex 2 – Maximum processes for examples of processes affecting the natural character of foods
Note that the use of minimum processes listed in Annex 1 does not automatically make the food product eligible for a natural claim. For instance, although "cutting" is listed in Annex 1 as a minimum process, the use of the claim "natural cuts" would be considered misleading if used in relation to a food product that did not meet all the criteria for a natural claim.
Note that some food additives, vitamins and mineral nutrients may be derived from natural sources. Some of these additives may be regarded as natural ingredients, in which case the acceptable claim would be that this food contains "natural ingredients". The processes used to produce the food additive should not significantly alter its original, chemical, or biological state. Note that while the ingredient can be described as "natural", the food itself cannot, since it contains an added component.
Use of the word "natural" in a trademark name is subject to the same criteria as outlined above. See Trade-marks for more information.
Regulated parties should be able to substantiate any "natural" claims. This may include providing information to consumers on the meaning of the claim (for example, via a website), by conducting consumer research to substantiate the claim, or other measures to decrease the likelihood that the reasonable consumer will be misled.
Substances that impart flavours that have been derived from a plant or animal source, may be claimed to be "natural". As well, any additive, such as preservatives and solvents added to a flavour preparation to have a technological effect solely on the flavour, does not modify the "natural" status of the flavouring material itself. However, the addition does alter the natural status of the food to which it has been added, even though it need not be declared as an ingredient on the food label. In other words, such foods may not be claimed to "contain only natural ingredients".
Furthermore, acids, bases, salts and sweeteners may be used to impart sour, bitter, salty and sweet tastes in conjunction with natural flavours. They do not alter the "natural" status of the flavouring material itself. For example, citric acid is not a flavour but acts only as an acidulant when used in conjunction with natural flavours.
Note, however, that while the flavour remains "natural", such acids, bases, salts or sweeteners have an effect on the foods to which the flavour preparation is added. Therefore, the list of ingredients of such foods must declare acids, bases, salts or sweeteners that are present by their common names.
The status of enzymatic flavours, processed flavours, reaction flavours or nature-identical flavours has not been established under these guidelines. Each one will therefore be examined on a case-by-case basis.
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