How does Label Insight determine which ingredients are from natural sources versus artificial sources?
Label Insight always aligns to established regulatory and legal documentation whenever possible for the purposes of creating attributes and the data elements that they are comprised of.
For the purpose of “natural” ingredient properties, Label Insight abides by the USDA’s National Organic Program (NOP), along with other official regulatory agencies such as FDA, INCI, and CODEX. The NOP states, a natural substance is derived from a plant, mineral or animal source, without having undergone a synthetic process. Physical and biological processes can still render a substance as natural. For instance, dried corn kernels can be removed from the cob, then milled to produce corn flour, or yeast used to facilitate the process of fermentation, yet these ingredients will still be deemed “natural”. For example, grapes must undergo a biological reaction in order to transform into wine, yet wine is considered a natural substance. This and other natural ingredients can be the result of physical and biological processes, even if they cannot be found in nature without the aid of these processes.
Label Insight considers a synthetic substance to be a compound which is made artificially through chemical reactions. However, whether or not a chemical reaction has occurred is not a reliable indicator to separate synthetics from natural substances since chemical reactions are part of nature, such as enzymatic browning. Human labor is also not a determining factor between a synthetic or natural substance. For instance, baking soda is an example of a chemical reaction which is created because of the addition of human intervention, but is clearly viewed as natural since the final results of the reaction are naturally occurring substances.
According to the FDA definition of color additives, all added color ingredients are considered artificial colors.
The term color additive is any material that is a dye, pigment, or other substance made by a process of synthesis or similar artifice, or extracted, isolated, or otherwise derived, with or without intermediate or final change of identity, from a vegetable, animal, mineral, or other source and that, when added or applied to a food, drug, or cosmetic or to the human body or any part thereof, is capable (alone or through reaction with another substance) of imparting a color thereto. Food ingredients such as cherries, green or red peppers, chocolate, and orange juice which contribute their own natural color when mixed with other foods are not regarded as color additives; but where a food substance such as beet juice is deliberately used as a color, as in pink lemonade, it is a color additive. 21 CFR §70.3(f)
Therefore, Label Insight uses the term natural color to indicate color ingredients from natural sources like “spirulina”, and “cochineal” and other colors derived from plant, mineral, or animal sources.
The term natural flavor or natural flavoring means 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 is flavoring rather than nutritional.
The term artificial flavor or artificial flavoring means any substance, the function of which is to impart flavor, which is not derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, fish, poultry, eggs, dairy products, or fermentation products thereof.
The FDA has rigid labeling regulation for flavors, therefore in the absence of a flavor designated to be artificial, Label Insight understands the flavor to be of natural sources. 21 CFR 101.22 (g).
The term chemical preservative means any chemical that, when added to food, tends to prevent or retard deterioration thereof, but does not include common salt, sugars, vinegars, spices, or oils extracted from spices, substances added to food by direct exposure thereof to wood smoke, or chemicals applied for their insecticidal or herbicidal properties.
Since the FDA doesn’t clearly distinguish the difference between natural and artificial preservatives, Label Insight uses the term natural preservative to indicate additives ingredients from natural sources like “Vinegar” and “Rosemary Extract” and other preservatives derived from plant, mineral, or animal sources.
While the FDA approves sugar alternatives for use in foods, they do not clearly designate natural versus artificial sweeteners. Therefore, Label Insight uses the term natural sweetener to indicate ingredients from natural sources like “Honey” and “Stevia” and other sweeteners derived from plant, mineral, or animal sources, regardless if they are non-nutritive sweeteners or sugar ingredients.
Label Insight includes additives like aspartame, acesulfame potassium, neotame, saccharin, sucralose and advantame in our definition of artificial sweeteners. Additionally, while sugar alcohols may be extracted from fruits and vegetables, they are most often manufactured. Examples of polyols include erythritol, isomalt, lactitol, maltitol, mannitol, sorbitol, and xylitol and are all considered artificial sweeteners for the purpose of Label Insight derived attribution.
What about corn syrup and high fructose corn syrup?
The FDA has confirmed that they would not consider HFCS natural due to the synthetic use of fixing agents and chemical restructuring during processing, and therefore we have given this ingredient as an artificial sweetener property. Alternatively, corn syrup is less processed and even eligible for organic status under the NOP regulations. Therefore, Label Insight considers corn syrup a natural sweetener ingredient.
Additional Information about High-Intensity Sweeteners: https://www.fda.gov/food/food-additives-petitions/additional-information-about-high-intensity-sweeteners-permitted-use-food-united-states