September 5, 2014, Global Food Forums, Inc. — The following is an excerpt from the Ingredion-sponsored “2013 Clean Label Conference Report.” Haz clic aqui ver en español.
The first step in clean labeling with flavors is to understand the regulations. A lengthy list of compounds that may be termed “natural flavor” is provided in Title 21 Code of Federal Regulations (CFR) 101.22. They include 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 are flavoring rather than nutritional.” Artificial flavor includes the substances listed in 172.515(b) and 182.60 of Chapter 21, except where these are derived from natural sources.
“Basically,” explained Gary Reineccius, Department Head of Food Science and Nutrition at the University of Minnesota, “if it is not natural, it is artificial.”
Labeling and naming of flavored finished products can become complicated and a bit subjective. For example, natural flavor added to a cherry pie filling, with sufficient characterizing ingredients (cherries), is labeled “cherry pie,” but natural flavor added to food with not enough cherries to sufficiently flavor the pie by themselves is labeled “natural cherry-flavored pie.” The added flavor now must be natural and cherry-like.
Foods containing artificial flavoring materials that simulate, resemble or reinforce a named or characterizing flavor must be labeled as containing artificial flavoring on the principle display panel. In determining whether added flavor does or does not simulate, resemble or reinforce the characterizing flavor, the principal test is to separate such added flavor from the product. Thus, vanillin added to chocolate would clearly not be a characterizing flavor, because it does not taste
“Benzaldehyde added to cherry juice would be considered artificially flavored, because benzaldehyde
reinforces and extends the cherry taste. The test is not solely whether an artificial flavor simulates or is chemically identical to the characterizing natural flavor, but also—more broadly—whether it resembles, reinforces or simulates it,” said Reineccius. In lemon pudding with citral and no lemon added for flavoring, the product would be labeled “lemon pudding, artificially flavored.” If a flavor
is natural and is derived totally from sources other than the product whose flavor is simulated, it is either labeled “artificially flavored” or “with other natural flavors” (WONF). If other natural flavors are added and the flavor contributed by the ingredient does not separately characterize the named flavor, then the regulations state that the front panel must say “lemon pudding with other
natural flavors,” for example, and the ingredient statement must list WONF.
In order to label a product with a blend of three or more distinguishable characterizing flavors, such as natural cherry, orange and grape flavors, or a blend with no primary recognizable flavor, the flavor may be declared by an appropriately descriptive generic term, such as “fruit punch” flavor. Such a product entirely flavored with artificial materials could be labeled in the same manner, but the ingredient statement must declare artificial flavors.
When labeling flavors contained in food products, their encapsulation matrices, flavor solvents and preservatives are typically considered incidental additives, added to a food as a component of an ingredient with no technical or functional effect, therefore exempt from labeling according
to 21 CFR 101.100.
Reineccius pointed out that the claim “all-natural” for a product is not the same as natural flavor. “Another claim often seen, ‘no additives,’ does not apply to GRAS substances, listed in CFR 1182.105 to 182.8997 and 184.1. GRAS substances are not considered additives,” he strived
In conclusion, an opportunity for a clean label often means natural flavor over artificial flavor, which typically adds substantial cost. Internal practices and corporate image come into play. Flexibility in labeling and interpretation of flavor characterization or simulation varies, industry-wide. WONF is frequently ignored.
Gary Reineccius, Ph.D., Professor and Department Head, Department of Food Science and Nutrition, University of Minnesota, firstname.lastname@example.org,+1.612.624.3201 http://fscn.cfans.umn.edu and www.flavor.umn.edu/
PHOTO of cherry pie from Cherry Mktg Institute