“All natural” and “clean label” do not necessarily equate with one another, began Deepthi K. Weerasinghe, Ph.D., Principal, dP3 Consulting, in his presentation “Formation of Flavor—Is Natural the same as Clean Label?”
In the absence of a regulatory definition for clean label and only vague guidance by FDA and USDA as to what constitutes “natural flavor,” such determinations are widely subjective. His presentation outlined a growing struggle between existing and evolving flavor production technologies and regulatory strictures working hard to keep up with shifting consumer expectations.Click for downloadable PDF
So, what constitutes natural? To begin, raw plant and animal products have generally been accepted as “natural.” However, their naturalness immediately becomes subject to interpretation, depending on whether genetically modified organisms, pesticides, antibiotics and/or other chemicals were used in their production and handling. Aspergillus oryzae, for example, is a filamentous fungus used to produce soy sauce, miso and sake. The growth media for A. oryzae cultures can be manipulated to create lactones as flavoring compounds.
“Since they are produced through natural fermentation, the lactones would be considered natural at that point, as they are not all that different from other products of fermentation, such as beer, yogurt, bread or cheese,” said Weerasinghe. But what happens when one starts genetically manipulating the enzymatic components of fermentative microorganisms?
Weerasinghe noted a patented process that converts kaurenoic acid into steviol and rebaudioside(s) (sweet components from the stevia plant) using genetically modified microorganisms. Companies need to be alert to such developments and their implications for clean and/or natural label designations.
It is also possible to manufacture colors through genetic modification. Weerasinghe cited a technical paper outlining how four bioengineered microbes could be used sequentially to transform glucose into callistephin, an anthocyanin color found in strawberries, pomegranate and blue corn. Would clean label consumers deem such an ingredient natural?
A demarcation between “soft” vs. “hard” chemistry may also define what is natural. Weerasinghe noted that the flavor industry had contended with this issue years ago with hydrolyzed vegetable proteins (HVP). While initially manufactured using “hard” inorganic chemicals to hydrolyze the proteins into amino acid-based flavor enhancers, consumer pressure shifted the industry toward using natural enzyme-catalyzed hydrolyses (i.e., “soft” chemistry).
This demarcation may not be quite so clear-cut today, especially under more restrictive EU regulations, said Weerasinghe. “Soft chemistry also refers to processing methods similar to common kitchen practices,” explained Weerasinghe, as in the use of juice concentrates and heat to manipulate pH conditions. Weerasinghe pointed to a patent describing the production of aliphatic alcohols and aldehydes from vegetable oils using enzymes naturally present in guava juices and soy flour. But, even then, he said, “The methodology used to extract and purify such enzymes will factor into their regulatory and clean label designations.”
The types of flavor extraction processes used also impact natural label designations. It makes a difference, he noted, if flavors are extracted with water, with ethanol (tinctures), or with natural oils or organic chemical solvents (oleoresins). Vanilla extractions typically use ethanol and water. However, the U.S. Code of Federal Regulations (CFR) also allows the use of glycerin, propylene glycol, sugar, dextrose and corn syrup in such extractions. Even such minor extraction-process modifications that could ultimately affect label designations.
Processed flavors, which rely on Maillard reactions and Strecker degradations to produce savory flavors, are regulated in terms of process conditions (temperature, time, raw materials) to determine what constitutes natural. In the EU, they must be called “processed flavors.” But their appeal also lies in the ability to create vegan meat flavors from vegetable proteins. “You can make a wide range of chicken or beef flavors without using animal proteins,” said Weerasinghe.
Whether or not they qualify as natural or clean label will depend upon both regulatory authorities—and where vegan consumers are willing to accept trade-offs
“Clean label folks don’t like black box ingredient designations like ‘natural flavors,’ because it doesn’t tell them what is in there,” concluded Weerasinghe. “Customers today are looking for safety; many are looking for comfort. Many customers have health challenges; they want protection from the unknown.”
The question remains: Are regulatory environments helping or hurting such aspirations?
“Formation of Flavor—Is Natural the Same as Clean Label,” Deepthi K. Weerasinghe, Ph.D., Principal, dP3 Consulting
This presentation was given at the 2019 Clean Label Conference. To download free presentations and the Post-conference summary of this event, go to https://globalfoodforums.com/store/clean-label-conferences/#2019
See past and future Clean Label Conferences at https://globalfoodforums.com/clean-label-conferences/