Abstract:
The challenge facing food ingredient, additive and flavourings manufacturers is to supply natural materials that comply with local regulations and accepted definitions of ânaturalâ. Fundamental disagreements between definitions of ânaturalâ for flavourings result in materials being classed as natural in one region of the world but not in another, creating problems for food labelling and international trade. For other ingredient and additive groups, food manufacturers and suppliers create the rules to suit in the absence of regulatory guidance. There is a clear need for a definition or sound guidance on the word ânaturalâ that can be applied widely across foods and food ingredient groups, is accepted by the general public, and will not mislead. This chapter reviews the definitions of ânaturalâ in international regulations and guidance and seeks to determine how they are applied, what natural actually means, and whether it is feasible to define it in a way that satisfies all stakeholders.
1.1 Introduction
We all instinctively understand the word ânaturalâ and at a superficial level we are all comfortable with its meaning. The consumer wants to consume natural food, and food companies and retailers are striving to satisfy that demand â nothing could be simpler. But when we start to delve into the deeper meaning of the word natural and apply this to food we encounter a number of problems and inconsistencies with the consumer âunderstandingâ of natural, the use of chemicals in food and the application of industrial processes to food.
The average consumer may understand that foods are packages of chemicals â some of low molecular weight and volatility that we can smell them, some water soluble that we taste, some creating the colour of foods, some vitamins and minerals that give nourishment, and some macromolecular polymers that our stomachs digest and convert to low molecular weight chemical nutrients such as sugars and amino acids. But the concept of a food additive, a chemical added to a food, contradicts in the minds of some consumers that instinctive understanding of natural, diminishing the wholeness and purity of the product, even though the chemical added may itself be natural and may provide significant benefits for the consumer. This is especially the case if the additive has an E number. Many natural food additives, such as beta-carotene (E160a) (also referred to as pro-vitamin A), have an E number and as such are not regarded as âclean labelâ.
The phrase âclean labelâ has been coined to represent foods that do not contain E numbers or chemical sounding names on the label in order to create a simpler, more consumer-friendly ingredient declaration with more natural and, for the consumer, comforting sounding ingredients. The phrase is also being used in a wider context to include foods in which the fat, sugar and salt content has been reduced offering a more healthy profile. The fact remains that many foods that are viewed as âclean labelâ do contain added E numbers because it is permitted to use the name in place of the E number. Hence âextract of rosemaryâ can be and is used instead of E392, and âascorbic acidâ or âvitamin Câ instead of E300, etc.
The industrial processing of food is also a mystery to consumers. Very few have seen inside an industrial-scale food factory and consequently there exists a considerable degree of suspicion about the âblack boxâ technology used by the food industry. These issues introduce a number of complexities when searching for a universally accepted definition of ânaturalâ.
The word ânaturalâ is defined in the Oxford English Dictionary as âexisting in or derived from nature; not made or caused by humankindâ. Likewise, the UK Food Standards Agency (FSA) defines natural when applied to food ingredients as âproduced by nature, not the work of man or interfered with by manâ (FSA 2008). These definitions have ramifications for food products and food derived ingredients because they imply that anything that is processed is not natural. This would mean that the wonderful smell of freshly baked bread, the tempting aroma of frying bacon, the steak on the barbeque, smoked salmon and fresh vegetables cooked to perfection are not natural. From a consumer viewpoint this is not an acceptable definition because all the processed foods identified above would reasonably be considered to be natural by the average person and consequently the chemical compounds formed during their processing would also be deemed to be natural. If we accept the purist view of natural then most of the flavour chemicals formed in processed food that deliver immense pleasure and satisfaction during eating would not be regarded as natural, because they are not present in nature and have been formed by the action of man from precursors in the raw food.
The majority of the food products we consume have been processed in some way through cooking processes, preservation techniques, or the assistance of microorganisms and enzymes. Even foods produced by nature such as fruits have been selectively bred over millennia and have been influenced by humankind. In fact it is very difficult to identify any food that, from a purist viewpoint, could be termed natural; perhaps raw fish consumed in countries like Japan and Holland, the witchetty grub in Australia, and honey (but even here the bees may have been sourcing nectar from selectively bred plants). We can conclude therefore that the bulk of the food consumed by the majority of people on the planet has been manipulated by humankind in some way. It is therefore important to identify a more appropriate and rational meaning for the word natural that can be applied to food, is generally recognised, and easily understood by consumers and can be used by food product developers and labelled in a way that does not mislead. This is not as simple as it seems.
1.2 The definition of ânaturalâ in the European Union
Turning to legal definitions of natural, nowhere has a definition been applied more rigorously than in Regulation (EC) No. 1334/2008 on flavourings (EC 2008) in the European Union (EU). Flavourings are defined in this regulation as âproducts not intended to be consumed as such, which are added to food in order to impart or modify odour and/or tasteâ. They are sub-classified into six categories: flavouring substances, flavouring preparations, thermal process flavourings, smoke flavourings, flavour precursors, other flavourings and mixtures of these. The term âotherâ is intended as a âcatch allâ definition and includes flavourings not covered by the five preceding categories. Article 16 of the Regulation prescribes which of the above groups can use the term ânaturalâ through the wording laid out below:
Use of the term ânaturalâ
Article 16.2
The term ânatural âfor the description of a flavouring may only be used if the flavouring component comprises only flavouring preparations and/or natural flavourings substances.
Only two of the six categories of flavourings therefore qualify for natural status. Flavouring substances are natural if they comply with the definition given in Article 3.29(c) of the Regulation shown below and all flavouring preparations are natural.
1.2.1 Flavouring substances
A flavouring substance is a defined chemical substance with flavouring properties and can be manufactured by chemical synthesis from petrochemical sources or using technologies that produce natural flavouring substances. It should be noted that the terms ânature identicalâ and âartificialâ no longer exist in the EU following the implementation of Regulation (EC) No. 1334/2008 and cannot be used to describe flavouring substances. The definition of a natural flavouring substance is outlined below.
Natural flavouring substances
Regulation (EC) No. 1334/2008, Article 3.2(c)
âNatural flavouring substanceâ shall mean a flavouring substance obtained by appropriate physical, enzymatic or microbiological processes from material of vegetable, animal or microbiological origin either in the raw state or after processing for human consumption by one or more of the traditional food preparation processes listed in Annex II. Natural flavouring substances correspond to substances that are naturally present and have been identified in nature.
This definition addresses the issue of the natural status of processed foods and recognises that foods that are cooked and the flavouring substances that are formed during their cooking are natural. Individual flavouring substances derived after processing for human consumption are natural...