Clean Label Regulations Presentation

Originally Published: June 30, 2017
Last Updated: February 14, 2022

The term “clean label” has no regulatory definitions, nor do many of the claims used on “clean labels,” so noted Chip English, Partner, Davis Wright Tremaine LLP. English spoke on the topic of “Emerging Clean Label Claims: Regulations & Liabilities”  at the 2017 Clean Label Conference. “Clean label” encompasses concepts from transparency, simplicity, and authenticity to natural and sustainable. To communicate their products’ desirable traits to consumers, the food and natural products industry is using similar far-ranging claims. Examples include clean; cage-free; free-range; grass-fed; local; fair trade; non-GMO; sugar-, fat-, gluten-, hormone-, dairy-, preservative-, artificial coloring-, and artificial flavoring-free; “simply from nature”; bare; stripped; unfiltered; and cold-pressed; among others. This presentation provided regulatory updates on existing and emerging clean label-type claims, and offers thoughts and advice on the use of more inventive, creative, and emerging declarations, as well as the business, reputation and litigation risks
of doing so.

An excerpt from the summary of the presentation:
“There are a whole lot of things that arguably could make clean label claims. But the meaning of some claims is not so clear. We still don’t know what ‘free-range’ or ‘cage-free’ are, and, although there are some hints of what ‘natural’ means, most such claims remain in the eye of beholder. What is ‘local’…10 miles, 50 miles, 100 miles? Does ‘local’ signify a different distance in New York City vs. in Des Moines, Iowa? Then, there are the emerging label claims: made from kitchen ingredients; craft; made from scratch; small batch, homemade…what do they all mean?” 

The entire can be read at

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