Decoding the Official FDA Definition: 21 CFR 101.22
For many consumers, the term "natural flavors" on a food label suggests a simple, wholesome ingredient, but the reality is far more complex. The official guidance can be found in the U.S. Food and Drug Administration's (FDA) Code of Federal Regulations (CFR), Title 21, Part 101.22. This regulation provides a specific definition for flavorings, differentiating between natural and artificial types.
The CFR defines "natural flavor or natural flavoring" as products containing flavoring constituents derived from specific natural sources. Its primary function in food must be flavoring rather than nutrition. This is a key distinction from actual food ingredients.
The Allowable Sources for Natural Flavors
Under 21 CFR 101.22, natural flavors can be derived from a range of natural sources listed in the regulation, such as spices, fruits, vegetables, edible yeast, roots, bark, buds, meat, seafood, poultry, eggs, and dairy products.
The Role of Processing
Despite their natural origin, these flavors undergo extensive processing, including methods like distillation, solvent extraction, and fermentation. The final flavor mixture can contain many chemicals and incidental additives like solvents, emulsifiers, and preservatives, which are not always listed separately on the label. The FDA permits these incidental additives if they are generally recognized as safe (GRAS).
Natural vs. Artificial Flavors: A Key Distinction
The primary difference between natural and artificial flavors is their origin. Natural flavors are derived from living sources, while artificial flavors are synthesized in a lab. However, the resulting chemical compounds can be identical.
Comparing Natural and Artificial Flavors
The full comparison between natural and artificial flavors can be found on {Link: Nutritional Sciences https://nutrisci.wisc.edu/2021/07/26/natural-and-artificial-flavors/}.
Navigating Flavor Labeling
Understanding how flavors are labeled is important for consumers. The FDA has specific labeling rules.
Generic Labeling: Products with a blend of natural flavors without a dominant recognizable taste can simply be labeled as "natural flavor".
Characterizing Flavor Labeling: If a product's labeling suggests a primary flavor (e.g., "strawberry"), specific rules apply. If natural flavor from the actual fruit is used but isn't sufficient on its own, it might be labeled "natural strawberry flavored". If the natural flavor mimics a taste but doesn't come from that source, it must be labeled as "artificially flavored". If both natural and artificial flavors are present, the label will indicate this.
Implications for Allergies and Dietary Preferences
The generic "natural flavor" label can be problematic for those with allergies or dietary restrictions. While major allergens must be declared, sensitivities to other substances potentially hidden within "natural flavors" are not explicitly listed. Natural flavors can also be derived from animal products, posing a concern for vegans and vegetarians. Consumers with specific concerns should contact the manufacturer for details.
Conclusion: Informed Choices for the Conscious Consumer
The FDA's definition of natural flavors is based on their source, but this doesn't mean they are necessarily minimally processed or healthier than artificial alternatives. Natural flavors undergo significant processing and can contain various unlisted additives. For truly informed dietary choices, consumers should focus on whole, minimally processed foods, carefully read ingredient labels, and be aware of the complexities of flavor labeling. The specific FDA regulations can provide further insight on {Link: Cornell University https://www.law.cornell.edu/cfr/text/21/101.22}.
