By Michael Pickering

While making my selections at the grocery store, I am often struck by the myriad of claims presented on food packaging.  I wonder what exactly qualifies a peach jam as “organic,” or a powdered diet beverage as “natural?”  Or when is a manufacturer allowed to claim specific health benefits from their product, or to declare that their food is a “good source” of a nutrient? My own experiences and growing curiosity have led me down this rabbit hole of exploration, and in sharing my discoveries I hope to add transparency to your next grocery trip.

At one time, specific nutrient descriptors were only loosely defined and the serving size was up to the discretion of the producer.  As you’d expect, this led to wildly different nutrition labels from one manufacturer to the next, even when comparing the same product.  Although there are still several misleading areas of food labeling (to be discussed), the regulatory push to standardize nutrient labeling, create serving sizes that reflect typical consumption, and plainly list common allergens has benefited today’s consumers.  It allows us to quickly compare two brands of the same product and determine the nutritional value of each.

Consistent serving sizes by product are now defined and enforced, and the serving measurements are required to be printed in both metric and common household units.  Health claims are required to follow more exacting guidelines – the amount of nutrient required to be present in order to claim a direct link to the health-related condition has been clearly defined.  For example, in order to print claims about reducing the risk of osteoporosis, a food must contain at least 200 milligrams of calcium, in a form that can be readily absorbed into the body.

In addition to specific requirements for claiming health benefits, manufacturers also must follow specific guidelines when using phrases like “free” or “fresh” or “source.”  For example: labeling a food as “Sodium Free” requires it to contain less than 5 mg of sodium per serving and not have any ingredient that is sodium chloride, and if the food occurs normally as being sodium free without additional processing or alteration, that must be disclosed.

During the last couple of years, I’ve seen a growing number of labels declaring foods to be “gluten-free.”  In line with my observations, the FDA recently implemented clear requirements for “gluten-free,” and any food that fails to meet the 20 ppm (20 mg of gluten in 1 kg of food) maximum will be prosecuted as misbranded.  Gluten-containing grains (wheat, rye, and barley) must be absent completely from the ingredient list, as well as any ingredient derived from a gluten-containing grain (such as flour).   In fact, I learned that food producers must now clearly label whether a product contains any of the most common allergens, which are responsible for 90% of all food allergic reactions.

Most Common Food Allergens
Milk	Peanuts	Shellfish	Tree Nuts	Eggs	Fish	Soy	Wheat

Organic foods follow strict criteria and regulation by the National Organic Program (USDA).  To be labeled “organic,” a food must consist of at least 95% organically produced ingredients.  There is a list of nonagricultural substances approved for use in the remaining 5% (which are not commercially available in organic form).  Organic foods are produced using approved organic farming methods, which prohibit the use of synthetic fertilizers and pesticides.  They also may not be irradiated or genetically modified.

The discussion of “organic” foods leads us organically into a discussion of “natural” foods, and here is where food labeling begins being less transparent.  The FDA defines “natural flavoring” in great detail, including specifying that a natural flavor may only be expressed in the food’s label if that flavor simulates the food from which it is derived.  For example, using a natural flavoring derived from an apple to make a juice taste of strawberries requires the manufacturer to either label it as “artificially flavored” or else to label the juice as containing “natural apple flavor.”  While on the subject of juices, the FDA declares that if a juice drink is less than 100% juice, it is not allowed to declare itself neither “100% natural” nor “100% pure.”

Interestingly, this is where the FDA guidance for “natural” comes to a halt.  There is no FDA definition or regulation of “natural” on food labels, beyond the previously discussed flavors.  The USDA has limited the use of “natural” to only indicate a product containing no artificial ingredient or added color and only minimal processing, but this only applies to the USDA-governed meat, poultry, and eggs.  The FDA has a longstanding policy (not a formal definition) to consider the term “natural” to mean that nothing synthetic or artificial (including all color additives regardless of source) has been added. Without further regulation, foods labeled “natural” can include high fructose corn syrup, genetically engineered ingredients, and any other plant-derived substances such as flavors or sweeteners.

When comparing foods as “organic” versus “natural,” I like to think of the analogy of a person describing themselves as “religious” versus “spiritual.”  Much like a religious person follows particular guidelines for their practice, so too is organic food grown with specific procedures and outcomes in mind.  In comparison, I think of a spiritual person as more fluid, with fewer specific rituals or at least less commonly-defined ones, and that would hold true for natural foods.  Natural foods are not rigidly regulated, which results in each manufacturer creating their own set of beliefs for what determines how “natural” their foods are.

Food for thought, when you are next out grocery shopping.