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Unnaturally confused


By Renee Mann and Michele Taylor

No TV party is complete without ample party snacks. So why not grab a bag of Nabisco’s Sweet and Salty party mix? It’s low-cal, with “natural flavors and other natural flavors” and artificial flavors listed on the ingredients panel. For the crackers and cheese platter, grab a can of Kraft’s Bacon-flavored Easy Cheese. It’s “naturally” flavored with monosodium glutamate, sodium nitrite, hydrolyzed corn protein and artificial flavors. Half-time flies by while friends enjoy the ads and munch on pizza. An excellent choice is Totino’s triple cheese. Not only is it “America’s best selling frozen pizza,” but it’s also “naturally flavored.” Never mind the artificial colors and mozzarella cheese substitute. Go (marketing) team go!

Companies are indeed scoring big in marketing their products as “natural.” According to the Nutrition Business Journal, the U.S. market for “natural” foods grew by 10 percent to $12.9 billion from 2007 to 2008. “All Natural” was the second-most-common claim on new food products launched in 2008. It’s not surprising then, that just about every product on grocery store shelves is marked as “natural.” Does “natural” or even better, “100% natural” mean fresher? healthier? safer? made with superior ingredients?

The Feds

“Natural is interpreted different ways by different people,” says Oregon Tilth’s technical specialist Gwendolyn Wyard. “The bottom line, however, is that there’s no legal definition for FDA regulated foods. The agency did not provide a definition in its Nutrition Labeling and Education Act due to resource limitations and other agency priorities.”

In other words, “natural” is a vacuous marketing term. When it appears on packaging and does not refer to specific ingredients, anything goes. This explains how “naturally-flavored” foods can have MSG listed on the ingredients panel. Consumers who are not up to date on the minutiae of FDA food regulations may falsely believe that foods labeled as “natural” are healthy.

The FDA certainly recognizes this. Last year, FDA Commissioner Dr. Margaret Hamburg addressed the National Food Policy Conference in Washington, D.C., saying, “The public health importance of food labeling as an essential means for informing consumers about proper nutrition . . . has not been substantially addressed since the FDA implemented the Nutrition Labeling and Education Act, more than 16 years ago.”

Lacking any legal definition, the FDA’s current policy is: “the use of ‘natural’ means that nothing artificial or synthetic (including all color additives, regardless of source) has been added. The agency does “not restrict the use of the term ‘natural’ except for added color, synthetic substances and flavors.” 

The words “natural flavor” and “natural flavoring” are another ball game. The FDA does provide food processors with a legal definition of them: they must come from: “the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional.” 

In spite of this very long and seemingly clear definition, there is still confusion about what a natural ingredient is. The FDA has deemed high fructose corn syrup to be natural, even though it is a highly processed corn product, unless it is manufactured using synthetic chemicals. The agency has also declared citric acid and ascorbic acid to be synthetic. But it has no opinion on whether or not ingredients like partially hydrogenated soybean oil, autolyzed yeast extract, hydrolysed soy and whey proteins or modified corn starch are “natural.” 

On a practical, grocery shopping level, the FDA’s “natural” policy and list of “natural” flavorings means that Quaker food manufacturers can sell “Cheesy Nacho” flavored Tortillaz brand “air baked rice and corn chips” with “Naturally Flavored” displayed prominently on its packaging and at least three artificial flavorings under the ingredients list: MSG, disodium guanylate and disodium inosinate. Tortillaz cannot be labeled “natural,” but they can be labeled “naturally flavored” because these words do not refer to the whole product, just a few, specific ingredients that are natural (tomato powder and onion powder). That’s what an under-resourced FDA gets you.

High steaks: the meat market

The U.S. Department of Agriculture steps into the game with labeling meat, poultry and eggs. In these cases, “natural” means: no synthetic ingredients, no chemical preservatives and only minimal processing are allowed. There are, of course, exceptions to the rule. For example, the USDA permits meat to be labeled “all natural” even when it has been injected with salt or broth. With no labels describing the added liquid content, consumers are paying premium prices for watered-down meat. Importantly, “natural” has no bearing on how the animal was treated or what it was fed. 

Despite the loopholes food manufactures can use to get their products stamped as “natural,” the USDA’s policy is more significantly policed than the FDA’s. The Food Safety Inspection Service (FSIS) must approve all USDA-regulated foods before it appears on grocery store shelves. “Natural” claims are therefore approved before products reach consumers. However, the USDA admitted in a 2009 Advance Notice of Proposed Rulemaking publication that there is an overall lack of consensus on how the FSIS addresses the “natural” claim on meat, poultry and eggs. 

Controversial “natural” claims are not limited to processed meats. Packages of ground beef, turkey breasts and chicken legs now feature the words “naturally raised.” The words conjure up beef cattle serenely grazing under blue skies, ambling from one clover patch to the next. Or poultry pecking their way around large coops at will. 

The USDA has a different vision of “naturally raised.” Last year, it defined the term as livestock not injected with antibiotics (except for control of parasites), growth hormones or animal by-products. 

It’s only a voluntary standard, and the Consumer’s Union wants it withdrawn. “This regulation will allow an animal that has come from a cloned or genetically engineered stock, was physically altered, raised in confinement without ever seeing the light of day or green of pasture, in poor hygiene conditions with a diet laced in pesticides to be labeled as “Naturally Raised.” This falls significantly short of consumer expectations and only adds to the roster of misleading label claims approved by USDA for so-called natural meat,” said Dr. Urvashi Rangan, Senior Scientist and Policy Analyst in a Consumers Union press statement. 

The organic regulation has much clearer standards for the humane treatment of animals. In November 2009, the National Organic Standards Board (NOSB) passed a recommendation to further define and strengthen the animal welfare standards within the National Rule. The recommendation proposes: proper housing for birds that includes not just cage-free living but access to the outdoors, exercise areas for swine that permit rooting and prohibiting practices such as de-beaking (for birds) and tail docking (for cattle).

On the Horizon
When it comes to organic foodstuffs, the USDA’s National Organic Program only allows non-synthetic ingredients that have been derived from minerals, plants and animals that have not been modified by a synthetic process, plus a small list of synthetic ingredients that have been reviewed by the NOSB.

Organic means almost entirely natural, but natural does not mean organic. This statement might seem obvious to organic food enthusiasts, but many consumers can be confused by these terms. 

Last year Horizon Organics called itself Horizon when it began selling Little Blends “natural” fruit and vegetable yogurt for babies. The packaging clearly defines the term as: “no artificial colors, flavors or preservatives, no high fructose corn syrup, from cows not treated with (rbST).” But, “organic” does not appear on the front label.


In fact, Little Blends ingredients include cultured, pasteurized grade A and organic non-fat milk. And although other ingredients are not organic, Horizon’s marketing communications manager Sara Loveday says that the products “could be labled as ‘made with organic ingredients.’”

Editors Note:"Made with organic milk" could be used if the product were certified. Just because they contain 70 percent organic doesn't mean the "made with" statement can be used.

In other words, Little Blends meets the 70 percent standard. But Horizon “opted not to label the product in that way,” she says. “When our Little Blends product was originally developed, we were unsure whether it would be made with organic milk or milk produced without added growth hormones. Due to the oversupply of organic milk, we chose to produce the product with organic milk and thus include it on the ingredient label. With this ingredient, the product could be labeled as “made with organic ingredients” but we opted not to label the product in that way, but rather highlight the primary benefits to our target audience."

If the company decided in the future not to use organic milk, it will not have to change its front label, but they would have to change the ingredient statement to reflect non-organic milk.

Already, Horizon’s switch from “organic” to “natural” with the same red packaging and bright red cow has led some to believe that Horizon is trying to fool consumers into believing these terms mean the same thing. 

The Western Organic Dairy Producers Alliance released a statement pointedly claiming that “the ‘natural’ label campaign has worked to confuse the consumer into thinking they are getting an organic product, when in fact, it’s just conventional milk with an organic price.”

“People believe ‘natural’ means healthy, but there’s no regulation,” says Honor Schauland, a campaign assistant at the OCA. She believes the label change from “organic” to “natural” was “a deliberate decision”--done for no other reason than to mislead consumers into thinking they are buying high quality products. It’s “unconscionable,” she says. 

Loveday asserts that for Horizon "The bottom line is that we are proud of our efforts to balance the interests of consumers, farmers and the organic industry. We listen to consumers who are searching for ways to feed their families healthy and nutritional products in a more affordable manner."

Three years ago, marketing and management assistant professor Jeffrey Anstine at North Central College, Illinois published an article in Journal of Applied Economics and Technology showing that consumers equate “organic” with “natural.” Anstine concluded that, “firms have been able to take advantage of confusion over the terms…and charge consumers more for the yogurt labeled “all natural.”

The Washington, DC-based Center for Science in the Public Interest (CSPI) is a non-profit organization trying to stop misleading “natural” labels on food packaging. Last year, it published Food Labeling Chaos, The Case for Reform, which calls for tighter government control on the claim. The publication states that food manufacturers who put prohibited substances—high fructose corn syrup, citracid, ascorbic acid—into their “all natural” products largely ignore FDA warning letters. “Unfortunately, both agencies (the FDA and USDA) have allowed deceptive claims to remain in the marketplace.” 

CSPI is recommending that the FDA restrict “natural” claims to products that do not contain artificial ingredients and provide a uniform standard of “minimally processed.” It is recommending the USDA prevent “natural” from appearing on meat that has been flavored with water and salty marinades and require manufacturers to prominently label added water content.

Snake venom and cyanide

According to a recent story in The New Yorker, synthetic flavors aren’t all that bad. In an article called “The Taste Makers,” author Raffi Khatchadourian’s explains how they are made. He writes that, “there is no molecular distinction between synthesized vanillin or vanillin extracted from vanilla beans, but the way the molecule is made determines whether it will be advertised as ‘natural’ or ‘artificial.’… Flavor chemicals often make up less than one percent of the ingredients in processed foods, and many flavorists regard the terms ‘natural’ and ‘artificial’ as largely meaningless – an indulgence for consumers who happen to believe that one is more likely to be toxic than another, even if the perception is not necessarily true. (After all, snake venom is natural.)” 

Robert L. Wolke made a similar statement four years ago in his Washington Post food column. The author of What Einstein Told His Cook: Kitchen Science Explained wrote, “many consumers appear to believe that natural is a synonym for good or healthful, as opposed to anything made or processed by humans, which is inherently evil and harmful.” He describes the natural chemical amygdalin, which comes from apricot and peach pits. It “reacts with stomach acid to produce hydrogen cyanide, the lethal gas that has been used to execute convicted criminals.” Wolke sites a taste-test carried out by Cooks Illustrated magazine to determine if people prefer natural vanilla flavoring to artificial vanillin flavoring. The fake stuff won.

The end zone

The Nielson Company’s Healthy Eating Report 2008 states that 55,000 “natural” items are available in grocery stores across the U.S. Some have artificial flavors (not to mention artificial colors). Most contain genetically modified ingredients. Meat and poultry products may contain un-naturally elevated levels of water and salt. If these products came from “naturally raised” animals, they were probably factory-farmed. Many consumers interchange “natural” with organic and don’t know what they are buying. 

In the United Kingdom, foodstuffs are labeled with easy to understand symbols to help consumers make educated choices about their purchases. Traffic-light colored dots are affixed to labels to indicate high (red), medium (yellow) and low (green) levels of fat, sugar and salt levels. The system was developed by the UK’s FDA equivalent, the Food Standards Agency, not corporate marketing teams, to help consumers quickly decide if a chosen product meets their health standards.

The CSPI aspires to better labeling laws in the U.S. In its Food Labeling Chaos, The Case for Reform, the organization states, “The FDA and the USDA should develop regulations instead of relying only on case-by-case enforcement actions. While the latter approach may signal to the food industry that the agencies are serious about enforcing the law, binding regulations are much more likely to ensure that companies do not break the law in the first place.”

Perhaps the most important game to watch is the food manufactures’ marketing teams vs. consumers and consumer groups who want to see an end to confusing food labels. At the moment, the marketing teams are on the offensive and winning the battle because they are making their own rules. By establishing rules everyone has to follow, the USDA and FDA can level the playing field.

Renee Mann works in DC. in the National Organic Program in the Compliance and Enforcement branch.

Michele Taylor is a Eugene-based freelance journalist.

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