The claim‘natural‘ stands out in labels and advertisements of many packaged foods. Very often, however, the call for naturalness is improper and constitutes a deceptive practice. When not outright fraud.
SAFE(Safe Food Advocacy Europe) is launching a petition for the European Commission to unambiguously define the conditions of use of the term‘natural‘, and similar wording, in food labeling and advertising. Reflections.
The natural chaos
The use of the ‘natural’ claim still lacks a uniform framework suitable for ensuring that this voluntary information meets consumers’ legitimate expectations about the nature and characteristics of a food and/or its ingredients. The wording under consideration is in fact regulated in different ways, in the various European regulations that variously consider it.
The REACH regulation-Registration, Evaluation, Authorization and Restriction of Chemicals (EU reg. 1907/06)-defines a ‘natural substance‘ as one that exists in nature, either unprocessed or processed by manual, mechanical or gravitational means only (e.g., filtration or percolation), by dissolution in water, flotation, water extraction, distillation, or evaporation.
‘Natural’ flavorings, additives unknown
The flavorings regulation (reg. EC 1334/08) in turn allows for the designation of ‘natural flavorings‘ as those obtained from naturally occurring matter. ‘Naturalness’ is, however, limited to the flavor substance, SAFE points out, as the same regulation allows ‘natural flavorings‘ to contain excipients, additives or preservatives of synthetic origin. So much for the transparency of consumer information.
The Additives Regulation (EC Reg. 1331/08), on the other hand, does not even contemplate informing the consumer about the matrix-natural or chemical-of the substance. Behind an authorization code (E…) can thus be concealed a tartaric acid extracted from grape lees or benzene, without the consumer being able to distinguish. (1)
Nutrition and health claims
The NHC regulation-Nutritional & Health Claims (reg. EC 1924/06)-in turn regulates the use of the terms ‘natural‘ and ‘naturally‘ with exclusive reference to the natural occurrence in a food ingredient or food of the nutrients, micronutrients or other substances that warrant a nutrition or health claim.
The result is admitting wording such as‘naturally high in fiber,’ for example, on breakfast cereals with added sugars, nightmarish nutritional profiles, and perhaps even food additives. By the mere fact that they also contain bran or whole grains. Viral deception.
The‘natural‘ claim in the Food Information Regulation
The Food Information Regulation refers to the general criteria of truthfulness (and demonstrability), clarity for the average consumer, non-deceptiveness and non-ambiguity of information offered on a voluntary basis (EU reg. 1169/11, Article 36). And the‘natural‘ claim is, in most cases, framed as voluntary ‘author-seeking’ news. On par with ‘artisanal‘, ‘traditional‘, ‘local‘.
‘To ensure that consumers are adequately informed, when food business operators provide voluntary food information that is conflicting and may mislead or confuse consumers, the Commission may provide, through delegated acts, (…)’ The criteria to be applied to ensure the non-deceptiveness and non-ambiguity of the information (EU Reg. 1169/11, Article 36.3).
As a result, the European Commission has been delegated authority to clarify the conditions under which potentially vague or confusing voluntary news can be used. And previous Commissioner Vytenis Andriukaitis promised that the executive would at least define the concepts of ‘suitable for vegetarians‘, ‘vegan‘. But it was a bluff, as already predicted.
Claim‘natural‘, of everything a little bit
‘Naturalness’ is more present on the shelf than in nature. Redounds on labels and advertisements for non-food products, from cleaning to personal hygiene, cosmetics, and pet food. And as if that were not enough-between legal designations, customs and cleverness-‘natural‘ is rampant in the descriptions of a variety of food products. In most cases, however, the term has a different meaning than ‘no use of chemicals.’
– in preserves, ‘natural’ is to distinguish the product immersed in preserving liquid. This wording is consistent with some productions (e.g., cooked and dipped tuna in brine) but not with others where products contain food additives (e.g., “cooked and dipped tuna in brine”). sulfites in canned vegetables, ferrous gluconate in ‘colored’ olives).
– In yogurt and other dairy products, the term ‘natural’ is traditionally used to express neutral taste. Without additional ingredients such as sugars, fruits and derivatives. And yet the shamelessness of marketing has gone so far as to use it even in sugary yogurts (e.g., Yomissimo), where the sugar is derived from processes that do not meet the notion of ‘natural ingredient‘ to ISO standards (see penultimate paragraph),
– in other products, such as sweeteners with stevia or fructose derivatives, ‘natural origin’ is boasted. But this is ambiguous information, since the only food ingredient in stevia is steviol glycosides, which are derived from a process that is by no means natural. And fructose itself, in most cases, is made by isomerization of corn starch. In short, nature is far from the table, (2)
– ‘Neutral‘ taste, with no additional flavoring ingredients added (natural, i.e., white, fruit-free yogurt, for example).
Claim‘natural‘, SAFE’s report
SAFE(Safe Food Advocacy Europe), a Brussels-based association, has collected a wide range of case studies of potentially misleading labels where the claim‘natural‘ recurs. In a report full of examples whose only flaw is having obscured brands.
The cases pointed out by SAFE pertain to the lack of specification of the nature-natural or not-of various ingredients and substances. Natural flavors in the first place. There is no shortage of cases of blatant misuse of the claim. See the ready-made dish that the Italian Fileni group presents as ‘natural’ although it contains various additives, including sodium glutamate.
Dietary supplements, the false illusions
Two particularly insidious cases of deception that SAFE highlights involve ingredients for supplements that consumers tend to think of as being of natural origin:
– Zeaxanthin is a carotenoid with antioxidant properties, useful in protecting eye health. Its synthetic replica was originally licensed under the name ‘synthetic zeaxanthin.’ But the European Commission, always ‘sensitive’ to Big Food lobbying, on 13.8.18 renamed the substance by removing the term ‘synthetic’. And so it is now impossible to distinguish natural ingredient from chemically synthesized ingredient on the label. Shame!
– Melatonin is a hormone produced by the pineal gland (epiphysis, at the base of the brain), which contributes to sleep regulation. It is often proposed in ways that suggest its naturalness. But instead it is still a molecule built in the laboratory.
SAFE petition on the ‘natural’ claim
The petition launched by SAFE – which can be signed HERE – aspires to obtain clear and uniform rules in the internal market within the European Union. In SAFE’s view, the use of the claim‘natural‘ should only come to be allowed if the product meets three requirements:
– Is free of GMO ingredients,
– does not contain synthetic substances (chemical additives) or the laboratory copy of substances existing in nature,
– can come to be associated with the concept of biodegradability.
The initiative deserves support, in this writer’s opinion, as it is useful in stimulating debate and spurring the Commission to exercise the delegation provided by the European legislature to shed light on equivocal wording.
Claim ‘natural‘, the ISO/TS 19657:2017 technical specification
ISO (International Standard Organization) published the technical specification ISO/TS 19657:2017, Definitions and technical criteria for food ingredients to be considered as natural. The regulatory bodies of the various countries and the representations of the stakeholders have thus defined the requirements to be applied for the purpose of our business-to-business communication only (business to business, B2B).
The ISO technical specification can be adopted as the basis for defining a binding EU-wide regulation on the use of the claim ‘natural,’ whether it relates to processes, ingredients and other substances, or to final products. To be applied to B2C(Business to Consumers) information as well as B2B information. ISO/TS 19657:2017 needs to be supplemented, however, in the writer’s opinion.
Claim ‘natural‘, what criteria?
The document prepared by ISO, as noted above, needs to be supplemented in several aspects:
– GMOS. The presence of or derivation from old and new GMOs(NBTs, New Breeding Techniques) of any substance used in production (including microorganisms, and feed in animal husbandry) is ontologically incompatible with nature and any call thereof,
– agrochemicals. Agrotoxic residues, not permissible. Reference is made to the deductions made on the case Organic Consumers vs. Twinings, which pertained to a ‘100% natural’ tea with pesticide and neonicotinoid residues,
– aromas. The ISO document establishes criteria to identify the actual ‘naturalness’ of non-aromatic components of substances. The name ‘natural flavorings’ should therefore refer only to flavorings that are truly such, ending the deception endorsed by reg. EC 1331/08.
Dario Dongo and Marta Strinati
Notes
(1) The debate on natural functional ingredients used to preserve meats (e.g., the Plant extracts. See https://www.greatitalianfoodtrade .it/etichette/conservanti-naturali-nelle-carni, https://www.greatitalianfoodtrade.it/tecnologia-alimentare/conservanti-naturali-nelle-carni-il-fico-d-india-studio-università-di-catania) and/or to color various foods (see https://www.greatitalianfoodtrade .it/mercati/molini-spigadoro-un-premio-all-innovazione).
ThePlants, Animals, Food and Feed (PAFF) Committee-which is attended by the European Commission and member state representations-interprets EU rules in an ultra-restrictive way. To the point of demanding that the aforementioned natural ingredients be subjected to the authorization and labeling regime provided for chemically synthesized additives.
With the obvious aim, brought about by Germany (Europe’s leading producer of meat and meat products) of hindering research and development of natural ingredients and thus preserving the market share of big industry, which persists in using the cheaper synthetic additives (e.g., nitrites). V. https://www.greatitalianfoodtrade.it/consum-attori/estratti-vegetali-nelle-carni-cortocircuito-in-europa
(2) Stevia sweeteners, moreover, often contain other ingredients (see https://www.greatitalianfoodtrade .it/etichette/stevia-bidone-made-in-bozen). Like erythritol, which is itself of distant natural origin, since it belongs to the family of polyols derived from cornstarch (see https://www.greatitalianfoodtrade .it/dolcificare/sorbitolo-e-altri-polioli-i-dolcificanti-di-massa). But it too, like steviol glycosides, is made by processes that are not compatible with the ISO standard defining the concept of ‘natural ingredients’
(3) See ebook ‘GMOs, the Big Scam,’ at https://www.greatitalianfoodtrade.it/libri/ogm-la-grande-truffa
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Professional journalist since January 1995, he has worked for newspapers (Il Messaggero, Paese Sera, La Stampa) and periodicals (NumeroUno, Il Salvagente). She is the author of journalistic surveys on food, she has published the book "Reading labels to know what we eat".
