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OTA submits final comments on ‘Natural’

In response to consumers who have requested that it explore the use of the term ‘natural,’ FDA is asking for the public to provide information and comments on the use of this term in food labeling. Although the agency has not engaged in rulemaking to establish a formal definition for the term, it has a long-standing policy that ‘Natural’ in food labeling means that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added. However, this policy does not address food production methods nor explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation.

FDA is requesting feedback on whether to pursue a formal definition of “natural” through rulemaking, and if so, how it should be defined. FDA is also exploring its relationship to the “organic” label and interested in any data or other information to suggest that consumers associate, confuse, or compare the term “natural” with “organic,” and whether it is perceived by consumers to be “better” (or not as good as) “organic?”  The comment deadline was May 10, 2016.

OTA Natural Claims Task Force

In response to FDA’s request for comments, OTA convened a task force to take a deep look at the issue. The mandate of the task force is to protect and uphold the meaning of organic claims in the marketplace. The task force is focused on identifying the risks and impacts that a formal definition may have on the organic label.


Over the course of the past five months, the task force has aggregated a range of available data from consumer research on the perception of natural vs. organic. Data demonstrate that many to most consumers falsely believe that “organic” and “natural” have similar meaning or at least share several attributes. More specifically, consumers falsely believe that the term “natural,” when used on food labels, comprises multiple attributes, such as “no toxic pesticides/fertilizers,” “no GMOs,” “no artificial colors or flavors,” “no artificial ingredients,” “minimally processed,” and “enforced according to a government standard.”


The survey data in its totality clearly indicate that consumers are confused by the term “natural,” they associate the term with “organic,” and they are misled by its use. OTA agrees that “natural” has no clear meaning and FDA should take action. 

OTA’s Final Comments

OTA’s comments are structured to first express the direction OTA believes FDA should take if the end goal is to protect consumers from misleading claims on labels. We have also included a list of outcomes we believe absolutely must not occur under any circumstance, followed by actions that must occur should FDA decide to pursue formal rulemaking and define the term “natural” according to consumer beliefs and expectations. OTA’s comments are based on aggregated consumer data and the identification of actions that may undermine the meaning of the “organic” label and/or duplicate or conflict with existing definitions within the organic regulations.

OTA’s Position

OTA believes the best course of action for eliminating consumer confusion and upholding the meaning of the organic label is for FDA to clarify its preference that, except where already provided for in FDA regulations (e.g. natural flavors), the term “natural” should not be used on food labels. Instead, we urge FDA to focus on defining the single attributes that may be used (e.g. “no artificial colors or flavors,” “no synthetic ingredients,” minimally processed,” “produced without the use of GMOs”) and engage in label guidance for their use on labels and marketing materials.


If the term “natural” is to be used, then we strongly urge FDA, in the same guidance, to identify and define a narrow scope of attributes that the term may be associated with and require an accompanying statement on the package label explaining its meaning.


            Example: “Natural – no artificial flavors or colors.” 


This would be the clearest way to eliminate consumer confusion surrounding the interplay between the terms “natural” vs. “organic” and the misleading use of the term “natural” in the marketplace.

Under no circumstance should the following be allowed:

  • When used on food labels, FDA should not extend the term “natural” to production methods (such as how something is grown) because this would be duplicative of the organic regulations and only create further consumer confusion. For labeling regarding attributes related to production methods (including growing and raising practices), FDA should direct consumers to the organic label.
  • The term “natural” should not be allowed on ingredients or food products that were genetically modified through the use of modern biotechnology (GMOs).
  • When used on food labels, the term “natural,” and the attributes used to describe it, should not extend beyond the scope of: 1) the composition or content of the ingredient/product; & 2) the extent to which the ingredient/product is processed.
  • Terms and subsequent definitions used to describe or define the term “natural” must not conflict or be inconsistent with the same terms and definitions found in the USDA organic regulations. Potential examples include “synthetic,” “processing” and “genetic engineering/GMOs.” This would only create additional consumer confusion and inconsistency between federal agencies.

 The following MUST occur should FDA decide to purse rulemaking

  • Any policy, guidance or regulatory definition offered by FDA should specify that all labels utilizing the term “natural” must include a statement explaining the meaning (such as "no artificial flavors or colors,” minimally processed," “no artificial ingredients”). By requiring such clarification, “natural” will be understood in its particular context—reflecting whatever single attribute applies to that product.
  • Should FDA decide to revise its policy and define “natural” beyond its current scope or the scope of USDA Food Safety and Inspection Service’s (FSIS) policy, then advocates and FDA should proceed through program establishment and rulemaking and ensure that processes are set up that include verification and enforcement mechanisms, including third-party certification, similar to the National Organic Program (NOP) for “certified organic.” Anything less would undermine the validity of the “natural” claim, leading to continued misleading labeling.

Again, OTA strongly believes consumer confusion would best be eliminated if clearly defined single-attribute claims, such as “contains no artificial ingredients” or “produced without the use of genetic engineering” appeared on product labels instead of the term “natural.”