It’s a well-known fact that consumers tend to assign higher health properties to products they consider natural. Use of the word ‘natural’ on a product label can boost sales and help customers feel goodwill towards a brand.
‘Natural’ is therefore an increasingly important claim to make for food and drink manufacturers, but what does it really mean and how do you know if you can use it?
Chris Preston from Legal Finesse, a boutique regulatory relations law firm, says the word ‘natural’ is not a regulated term in the food standards code, which means it relies on its dictionary meaning.
There are numerous meanings for ‘natural’ listed in the Macquarie Dictionary, however, which leaves things open to interpretation.
The official word
Australian regulators have addressed the topic, albeit briefly. According to the Australian Competition and Consumer Commission (ACCC), the terms ‘nature’, ‘natural’, ‘mother nature’ or ‘nature’s way’ can be misused on food and beverage labels.
“These claims often suggest that a product is superior because it has certain ‘natural’ characteristics as opposed to being processed or artificial or otherwise removed from its natural form,” the ACCC says.
The ACCC has dedicated a few paragraphs to clarifying the topic in its 'Food and bever age industry: food descriptors guideline to the Trade Practices Act'.
The ACCC also points to the Macquarie Dictionary definition of ‘natural’ which it summarises as “something that existed in, or was formed by nature; i.e. not artificial, or something that is based on the state of things in nature; i.e. constituted by nature, or is true to nature, or closely imitating nature”.
According to the ACCC, this means it may be misleading to use the term ‘natural’ to describe foods that have been altered by chemicals.
The ACCC also notes that consumers may view what is ‘natural’ differently to manufacturers and food technologists.
“When providing a label with a claim that the product is ‘natural’, thought should be given to what the consumer would think,” it notes.
The nuts and bolts
So where does that leave food and drink manufacturers? According to Preston, there are a few key concepts that should help to clarify the issue in the absence of more specific guidelines.
For starters, he says, if you claim your food is natural, you are really saying that all your ingredients are natural.
“If they’re not, you’d be better off making some other claim, such as ‘with natural wheat’ for example,” Preston says.
He says the ACCCs guidance around chemical altering of food could also be extended to other methods of altering foods, such as heating oils, for instance, which can change their chemical composition. It’s largely a question of consumer perception, he says.
Then there are extracts. Some are fine, he says, depending on the intensity of the extraction process. Highly refined fruit extracts, for instance, may be the considered the latest superfood, but the important question centres on how the extraction occurred, Preston says.
“Was it purely physical, did they use heat or water, did they have to mash it, dissolve it in alcohol, dry it out, put it through a still, or add some chemicals?” he says. “That’s the touchstone: whether the use of natural is misleading to consumers.”
According to Preston, foods that include artificial preservatives like sulphur dioxide and sorbate, can’t be called natural.
He also advises manufacturers not to rely on overly technical analyses to claim something artificial is natural.
“You have to come back to the ordinary definition: what consumers understand,” he says.
Nature identical
Nature identical products, which are synthesised but are chemically identical to a natural product, require special treatment on a label.
Preston suggests companies don’t rely on the idea that because they closely imitate nature, they can be classed as natural.
“The general feeling is that consumers probably wouldn’t agree in the food context that these things are natural,” he says.
But by the same token, these aren’t considered artificial either, so you would be allowed to say “no artificial additives” on the label.
Also, just because something is derived from a natural source, it doesn’t mean consumers would see it as natural, Preston says. For instance, some products are derived from petroleum, which is technically natural, but is not a natural food.
He says there are also a range of common sub-ingredients, like vinegar, that can be produced using a number of methods, some of which would be considered natural and some that wouldn’t. “Sometimes you do have to ask the question: what’s the source of my vinegar?” he says.
Preston says there is a common, but not necessarily accurate, belief that because something is natural, it is therefore better for you. This, he says, might drive marketers to wrongly label their products as natural.
“If they’re up against it, they might be tempted to stray across the line,” Preston says. “Label space is gold. The reality is that as much as you’d like to use that one word, sometimes you need to qualify and explain a little further.”
Natural notes
- If you claim your food is natural, you are really saying that all your ingredients are natural.
- Altering food using heat, extraction or chemicals may affect a product’s ‘natural’ status.
- Foods that include artificial preservatives like sulphur dioxide and sorbate can’t be called natural.
- Nature identical products can’t be described as natural.
- Something may have a natural source (e.g. petroleum) but that doesn’t mean consumers would see it as natural.
- Some sub-ingredients, like vinegar, can be produced using a number of methods, some natural, some not.
