When I talk about natural, I’m talking about it from the viewpoint of a flavorist,” Simon Poppelsdorf, R&D Flavors Division at Bell Flavors & Fragrances, told attendees of the NAFFS 99th Annual Convention. The presentation explored three parts of natural: the perception of natural, definitions on natural and general discussion.
There is much confusion today due to the fact that more than one definition exists for natural, Poppelsdorf said. “Starting with the perception of natural, there’s a question mark. What is correct?
Natural? Safe? Chemical? Healthy? Artificial?
“When you listen to consumers – and for us consumers is another word for customers – ‘natural’ in the consumer’s mind is connected with everything good – natural, safe, healthy,” said Poppelsdorf. At the same time, he said, consumers believe ‘artificial’ is associated with chemicals and not good and not healthy.
These types of messages are mainly driven by marketing and not by science. “Just as a reminder, natural is as chemical as artificial,” said Poppelsdorf. “Those two terms have nothing to do with each other. But a constant barrage of marketing and ‘product information’ is teaching the consumers that natural is free of any chemical. You only have to look at Proposition 65 in California to learn that there are as many natural as artificial chemicals dangerous for the consumer.
“The chemical reality is that whether a substance is entirely new, copied or extracted from nature, it tells us nothing about its intrinsic safety,” said Poppelsdorf. “Likewise the terms ‘industrial,’ ‘Synthetic,’ ‘Artificial’ and ‘Man-Made’ are by no means non-safe. ‘Natural’ does not necessarily mean better or safer.”
Referencing a slide on all-natural strawberries, Poppelsdorf noted “this is what we are showing people when they talk about chemicals or a chemical-free society.” The slide was from a science teacher in Australia who attempted to explain the chemicals in natural fruit.
“Today you hear phrases such as ‘chemical-free society.’ What is that? And people will say they’re not using any chemicals. Well, guess what? You are a chemical,” said Poppelsdorf. “So we have to have a talk about it. It does not exist and if somebody is willing to take this to the extreme, you die. It’s as simple as that.
“Now if this is used as a metaphor for no additions, clean label, carbon footprint or organic, I can understand that but it worries me that in all this there is no real discussion about what you feed your child and whether from the nutritional side whether it is good or bad,” said Poppelsdorf. “I believe this is happening because the average consumer is too far detached from the actual process of preparing the food they consume.”
Poppesldorf said the food industry has not communicated effectively to educate the consumer about what they actually eat. Why not, he asked, share your process of making the food you present?
“Keep in mind that every chemical is inherently dangerous and non-dangerous. That is why the very wise people that started the FEMA GRAS list introduced ‘intended use.’ “Safety is about the use of a product – not the product itself.”
“The definition that we live by in the industry for natural is the FDA definition on natural flavors. By the way, this is the only definition we have that exists for natural. FDA has been forced into taking a general stand on natural. There was a lot of pressure on the agency to come out with a definition on natural for foods and flavors,” Poppelsdorf said. He highlighted the last sentence in the message FDA sent out, saying it did not describe any nutritional or health benefit. “Of course, what FDA is trying to do is focus on safety. It’s a repeat of an action in 1991 for FDA. At that time they also got a lot of questions. They started the process but never finished it. The action this time around was not taken by the FDA. It was taken by Congress with a lot of pressure from NGOs that there has to be a definition in the food industry to live by and it’s created more confusion,” Poppelsdorf said.
Poppelsdorf made a compilation of some of the comments that were submitted, saying that many commenters are not talking about safety; they are talking about feelings.
“It is a pretty simple concept. The word, “Natural” in the dictionary means: existing in or caused by nature; not made or caused by humankind. As such, any ingredient that is made by artificial, synthetic or genetically modified means it cannot rightfully be “natural.”
“Basically if you put something in it or on it that a child cannot spell, it isn’t natural. If it has additives or preservatives, it is not natural. If you add sugar to milk, it is no longer natural.”
“Natural = organically grown, unprocessed, nothing added, minimally packaged.”
FDA has received roughly 5,000 comments. Among the comments submitted, the Grocery Manufacturers Association is asking for a clear definition of ‘natural’ and many consumers submitting comments are confused between natural and non-GMO. Many, he added, think all ingredients should be natural and no colors and other approved ingredients should be allowed.
Is sugar natural? (uses sulphites)
Is HFCS natural? (uses enzymes)
Poppelsdorf said the FDA has a difficult task to solve the issue. “On one side you’ve got all the emotions about natural that the consumer believes. And the only solution the FDA has is to go back to the safety issue and define natural as a product that is safe for humans – wherever that is coming from. It will probably come down to be something like truth in advertising where there will be restrictions on the front and back labels. The curious part will be how FDA will scientifically defend the stance it takes compared to what the consumer is expecting FDA to do,” he said.
“On top of that, you get companies like Whole Foods and Trader Joe’s that are each putting more restrictions on what we can do and further defining what we can call natural,” Poppesldorf said. “It doesn’t make our lives very easy when you are talking about developing flavors that will taste good. It doesn’t end there, he added. The Non-GMO Project and the National Organic Program are adding an additional layer to all the definitions discussed today. “It might be interesting to take a look at what the EU has done with this. They basically eliminated the declaration of artificial flavor for just the word “flavor.” Maybe that is the way we should go,” Poppelsdorf said.
Pointing to a slide, Poppelsdorf referenced the legal guidelines for labeling flavors. [put FDA guidelines for flavor labeling slide here] He cited differences between the U.S. regulatory agencies. FDA defines what is considered “natural flavor” in every food product not regulated by the USDA. The USDA defines “natural flavor” for meat products differently from other food products. Its definition is completely different from FDA. USDA Natural is a product containing no artificial ingredient or added color and is only minimally processed. Minimal processing means the product was processed in a manner that does not fundamentally alter the product. The label must include a statement explaining the meaning of the term natural (such as “no artificial ingredients; minimally processed”). The flavor industry is struggling because of the lack of consistency, he said. “You can get a different ruling from different USDA field offices on the same flavor due to the very wide leeway in defining ‘minimal processing,’” he said.
FDA Natural means that nothing artificial or synthetic (including colors regardless of source) is included in or has been added to the product that would not normally be expected to be in the food, he said.
Next, the TTB natural definition was reviewed. “TTB is basically a product that allows you to take a flavor, add 0.1 percent of artificial ingredients, use artificial coloring, and still call it natural,” said Poppelsdorf. “I’m not sure that everybody outside the alcohol industry understands what that definition is. There is more to this in respect to so called ‘controlled substances’ but this is outside of our discussion today. I just want to make the point that this is an additional definition of natural in the market.”
Looking at the current position of FDA, Poppelsdorf said the agency will maintain its current policy…not to restrict the use of the term “natural” except for added color, synthetic substances and flavors as provided in [21.CFR]101.22. Additionally, he said, the agency will maintain its policy…regarding the use of “natural” as meaning that nothing artificial or synthetic (including all color additives regardless of source) has been included in or has been added to a food that would not normally be expected to be in the food. But Poppelsdorf thinks they will look at labeling and send letters out if they think it’s going too far.
Poppelsdorf provided an overview of the EU definition of natural, noting it is similar but not the same as the FDA definition. “Generally speaking,” he said, “if you have a product that is considered natural in the EU, it will be natural in the U.S. But the reverse is not true. If you have a product declared natural in the U.S., you have to be careful calling it natural in the EU. And you have to get back to your supplier about any processes used. The EU Flavouring Regulation indicates that ‘a 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’ can be labeled as natural.
Then there’s the “never natural” category, he added. “It is important to note that when we talk about natural flavors, all ingredients are not part of the natural definitions because there are food ingredients separately approved by the FDA,” said Poppelsdorf.
He outlined the challenges industry faces when creating a flavor:
● Toxic ingredients
● Unavailable raw materials
● Character named products
● EU, Canada
● Definitions of Natural, artificial, WONF, N&A
● Different interpretations between USDA and FDA
● Different from country to country
● Security and safety
● The Food Safety Modernization Act (FSMA)
● IFRA Amendment 48
● Prop 65
● Na, nutrients, calories
● Where is the finished product sold?
● How is it shipped?
● Flash point and HAZMAT
● Global Harmonization System
● SDS June 1, 2015 in the USA
● Customer restrictive lists
● Whole Foods
● Trade Joe’s
● Customer specific lists
● Non-GMO project
“When dealing with food, natural definitions are only one important but small part of the challenges we face in the day-to-day development of flavors and food,” said Poppelsdorf. “An interesting discussion in itself to have is let’s assume we all go ‘natural’. All ingredients…all aroma chemicals…all extracts. Will the world be a better place? Will it be safer? Will it be healthier? As I mentioned earlier, the total crop of vanilla beans only covers 1 percent of the total global demand. The total production of natural vanilla is approximately 2,000 metric tons a year. It is estimated that there is a need for 15,000 metric tons per year. It’s virtually impossible to go all natural to meet demand,” he said.
What is the effect on the environment? Maybe, Poppelsdorf said, the artificial production of flavors might be an environmentally better way of producing materials than the natural material. “When you talk about artificial vs. natural, sometimes people don’t understand the processes to obtain natural materials are not necessarily ‘safer,’ ‘environmentally friendlier,’ or ‘creating a lower carbon footprint.’ In fact, sometimes it’s even contrary. So the question is why do this when we agree that it does not make any difference for our body or make the food we eat safer or more nutritious?
“Again, I am drawing a line to Non-GMO,” said Poppelsdorf. “The research on non-GMO started because we did not want to use DDT anymore alarmed by the book ‘Silent Spring’ from Rachel Carson which, for the first time in 1962, discussed the pollution of the oceans around us by runoff of pesticides. We should stop that.”
How do you find the sweet spot? “This is something we struggle with every day in the lab because the sweet spot for development is getting smaller and smaller every day. An average flavor house has around 2,500 raw materials in stock – 1,500 artificial and 1,000 naturals. Now this flavor house wants to sell Organic, EU-approved and Non-GMO approved flavors. Guess what is happening to the number of raw materials in stock?
“Let’s take as an example Fenugreek OR – a widely used materials for years. You may have had only one item in stock and found it contains PG and caramel color. So you get one without, then a Non-GMO version of it and then an organic version of it. And in case you are wondering why not consolidate, the answer is the difference in cost of the existing flavor that you sell. No one wants to talk about the financial impact but in order to serve the food industry what they want, there is a big impact on cash flow and other economic indicators when everyone wants everything ‘all natural’. And when it comes right down to it, no matter what is being requested, the consumer will only eat something that tastes good.”
Poppelsdorf concluded his presentation by referencing slides that debunk a lot of assumptions people have about chemicals in general:
“When it comes to talking about natural, I think we shouldn’t be talking about natural vs. artificial or natural vs. chemical. What we should be talking about is safety and that what we are doing is safe.” He reminded everyone about the example the industry has with the GRAS list. “The wise people who set up the GRAS list didn’t have a description about natural or artificial. They worked with a description about safety. And when you look at the GRAS list, you will see that there is an ‘intended use’ there. Every chemical – be it natural or artificial – has an intended use,” said Poppelsdorf.
Demonstrating his point Poppelsdorf concluded with an example: “If I eat 4 grams of salt per kilo of body weight, I’m dead. Is salt, therefore, poison? No. But if you eat too much, it’s harmful. So that’s the message we need to get across to the consumer – that it is not about the chemical itself but rather how it’s used in food. It’s about the application of the chemical that is present in nature or is present artificially.”