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Naturally Processed?

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This post was written by Janelle Langan, a Global Health Law LL.M. student at Georgetown Law. Any questions or comments about this post can be directed to
Recent emphasis upon diet through consumer education, media coverage, and mobile food journaling applications has brought healthy eating to the forefront of the minds of consumers. A healthy diet is a preventative measure that can help combat various diseases and conditions. In response to consumer focus upon diet, the market for healthy foods expanded from its’ niche origins into a prevalent force in the mainstream food marketplace.

A wide-range of food products are labeled as “natural”, “all natural”, “100% natural”, “naturally grown”, and “made with natural ingredients.” These products include juices, granola bars, cereals, canned goods, and tortilla chips. Consumers are willing to purchase “natural” food products at a premium price because they perceive these products to be a healthier choice. However, foods labeled as “natural” are not always healthier as this label is used to attract consumers to the product rather than inform consumers about the quality of ingredients.
Consumers may be surprised to learn that food labeled as “natural” may contain high fructose corn syrup, genetically modified organisms, and additional non-natural ingredienWill-all-natural-be-phased-out-from-product-labelsts. The definition of “natural” is extremely ambiguous because federal agencies are unwilling to put forth a legally binding standard. The Food and Drug Administration (FDA) is responsible for ensuring that food products display proper and accurate labels.[1] The FDA avoided officially defining the term “natural” because the FDA contends that food products are no longer “a product of the earth” as they are processed to some degree.
The FDA has put forth a non-binding policy explaining that “natural” means “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 that food.” This subjective definition allows food manufacturers to determine how to apply the term “natural” to their food product labels. Additionally, the non-binding policy does not address 1) food production methods, including the use of pesticides; and 2) the nutritional or health benefits. Therefore, contrary to common belief, food products labeled as “natural” are not necessarily healthier.
In response to recent litigation as well as Citizen Petitions, the FDA has recently begun to accept public comments on the following issues:

  • Whether it is appropriate to define the term “natural”;
  • If such action is appropriate, how should the FDA define “natural”; and
  • How the FDA should determine appropriate use of the term “natural” on food labels.

A formal, robust definition of “natural” the FDA would be a progressive step forward because it could 1) provide guidance to the judicial system: and 2) inform consumers and food manufacturers of the specific label standard of “natural.”
[1] Note: This article focuses on the food labels within the scope of the FDA. The United States Department of Agriculture, Food Safety and Inspection Service oversees the labeling of egg, poultry, and meat products.

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