SUMMARY: Marketing is what’s found on the front of food packages. “Pure,” natural, wholesome, ancient, “healthy,” low-carb, low-sugar, doctor-approved, and yes, even “organic.” “Big Food” is counting on YOU to be a surface-level consumer; trusting what you read on the front of bags and boxes, and buying more. Prove them wrong by becoming a very good investigator. Turn the package over; read the list of ingredients, and research anything you don’t understand before purchasing.
By Liz Quinn
In the eternal quest to make healthful food choices, ditching a trip through the drive-thru for a trip to the grocery store might feel like a victory. However, a deep dive into the average shopping cart may yield unexpected concerns. After all, products that contain added flavors make up 90% of Americans’ grocery purchases.
A label-conscious consumer may see “natural flavors” on a package and feel good about purchasing that item over one labeled “artificial flavors.” While natural is generally thought of as more wholesome and safe, the meaning of the term “natural flavors” is worth a closer look.
This is especially true, given that “natural flavors” are now the fourth most common food ingredient in America, according to the Environmental Working Group—surpassed only by salt, water, and sugar. With this level of prevalence, it’s understandable that consumers would want to know what that term actually means.
What Are Natural Flavors?
Unfortunately, the FDA’s definition is so broad it’s difficult to specify, and therefore to test and ensure that every chemical, compound, or process used in the creation of natural flavors is 100% safe. To qualify for a “natural flavor” label, the FDA requires the flavor be derived from an edible plant or animal source.
Being a GMO (genetically modified organism) also does not preclude a flavor from being dubbed “natural.” When it comes to processing, there are few limitations: for example, “isolation of natural flavors through chemical transformation by inorganic catalysts meets the U.S. natural flavor requirement.”
In terms of safety, the Flavor Extract Manufacturer’s Association (the lesser-known FEMA) has compiled a list of flavor compounds that are generally recognized as safe (GRAS). FEMA assures that these compounds have been researched and rigorously reviewed.
However, the GRAS list ultimately comes from FEMA and its scientists, not from the FDA. Further, “food companies do not need to disclose the ingredients of flavor if all of the ingredients, which can be up to 100 in one flavor, fall into the GRAS category.”
Companies are strongly encouraged, rather than required, to submit their GRAS determinations to the FDA. A 2010 Government Accountability Office report expressed concerns about the voluntary nature of the GRAS system:
“Once a GRAS substance has entered the marketplace, FDA would find it difficult to identify that substance as the potential source of a food safety problem, especially if FDA is unaware that the substance has been determined to be GRAS.”
A Molecule Is a Molecule?
Food scientists, otherwise known as “flavorists,” who spend seven years apprenticing to learn the craft, tout natural (and artificial, for that matter) flavors as carrying little risk because, in the end, the flavor molecule they create may be close, if not identical, to the flavor molecule they’re trying to imitate.
Some would even argue that artificial flavors have advantages over natural: because they’re crafted in a lab, they may be more pure in the end than flavors derived from nature, with a vast array of components; coming from a lab could potentially lessen environmental impact, as with vanilla.
The world’s most popular flavor, pure vanilla, comes from hand-pollinated flowering orchids grown in the tropics. Certainly, making vanilla in the lab from a natural source is less cumbersome and costly, but perhaps nature has a purpose to the other compounds in a vanilla bean. Pure vanilla extract has been found to have as many as 250 taste and aroma components.
Such components may serve a yet-undiscovered function, but flavorists boil it down, figuratively, to the vanillin molecule…often with the intent of enticing the consumer to eat or drink more.
Science and Intentions
Among the reasons for adding flavors to foods, are replenishing the tastes that processing methods like pasteurization tend to remove. Also to allow for a longer shelf life while maintaining a fresher taste, and to persuade consumers to eat (and therefore buy) more. To this end, the food industry employs those very specific aforementioned scientists, the flavorists.
Two such flavorists from Givaudan, one of the largest flavoring companies in the world, discussed their work in a 2011 interview on 60 Minutes. Among their goals as flavorists, they said, “You don’t want a long linger, because you’re not going to eat more of it if it lingers.” Interviewer Morley Safer asked point-blank, “You’re tryin’ to create an addictive taste?” to which the flavorist replied, “That’s a good word.”
Because the FDA does not require food companies to disclose to consumers all of the ingredients that comprise a “natural flavor,” the consumer is left with no way of knowing if there are components that could affect people with sensitive or uncommon allergies, and those with restricted diets.
Further complicating the murkiness of the “natural flavors” term are hidden ingredients in the form of carriers, such as maltodextrin, as well as the processing itself, where components like manufactured free glutamate (MfG), can sneak in without necessarily being declared.
Truth in Labeling, a campaign for food transparency, argues that it’s the manufactured free glutamate in monosodium glutamate (MSG) that causes harmful reactions in certain people. If MSG is an actual ingredient in a food, it must be listed on the label.
However, if it is used toward creating a natural flavor, it is considered a processing aid and not required to be declared on the label. MSG is of concern in that it’s considered an excitotoxin—a substance that can excite neuron receptors, sometimes to the point of damage, or even destruction.
Maltodextrin, a carrier often used as a thickener or filler, originates from plants such as corn, rice, potato, or wheat, so it qualifies as a natural flavor, but its glycemic index of 106-136 is considerably higher than table sugar at 65, a concern for everyone, but specifically diabetics, and those up against prediabetes and metabolic syndrome.
In a 2012 study, researchers also found maltodextrin increased bacterial growth of E. coli and altered gut bacteria composition, an increasingly important factor in health.
Other Countries’ Definitions and Regulations
Like the U.S., the EU requires that a natural flavor originate from a vegetable, animal, or microbiological source. However, they also require that natural flavors be manufactured only by traditional food preparation processes; use of synthetic, inorganic, or chemical catalysts does not qualify.
Natural flavors in Japan must fall within a limited list of plants and animals as the source.
India has one of the more stringent policies, allowing the natural flavor label only for those “derived exclusively by physical processes from vegetables.”
The difficulty in demanding more precise labeling for “natural flavors” lies in the breadth of its FDA definition. Because virtually any plant or animal source and a multitude of processing methods are acceptable under FDA requirements, the reality of testing the health outcomes of each specific one, let alone in combination, by non-industry, objective scientists, is unlikely.
If the FDA required companies to list every specific ingredient used in natural flavors, they may well not even fit on a label.
Director of FDA’s Office of Nutrition and Food Labeling, Douglas Balentine, stated, “Ultimately we want consumers to be able to make informed choices about their foods, and FDA’s job is to make sure consumers know what they’re getting.” But when it comes to natural flavors, consumers are kept in the dark.
It’s not entirely unreasonable that food companies would be reluctant to add every ingredient on a label. Aside from the proprietary aspect, the reality of a food label with every single chemical compound used would likely scare off even the most label-lax consumer. After all, the word “chemical” has a bad connotation, but we are all made up of chemicals. For humans, that chemical is primarily dihydrogen monoxide, aka water.
As QR (machine-readable) codes are already becoming ubiquitous on product labels, the FDA could require companies to disclose their natural flavor ingredients that way, or via an easily-accessible website link, without amounts in order to keep trade secrets.
Absent FDA requirements, a voluntary disclosure program similar to what the Non-GMO Project does with non-GMO verification could help consumers. If companies wanted to participate and disclose ingredients, they would likely increase both customer trust and profits.
Short of the seemingly lofty goal of buying everything fresh, whole, and unprocessed, what’s a shopper to do? Although manufacturers don’t have to list the substances that comprise natural flavors when using them, they are required to include the term “natural flavors” within their ingredients. Look for packaged products that don’t list natural flavors at all in their ingredients—they do exist.
When possible, choose organic. An organic natural flavor distinction means the flavor has to contain at least 95% organically-grown base ingredients and may not use synthetic extraction solvents. Among other requirements, the manufacturer must ensure the organic natural flavor “not contain propylene glycol, any artificial preservative, is not extracted with the chemical solvent/cleaning agent, hexane,” and is non-GMO.
For safety concerns about specific flavor components, the FEMA flavor library allows anyone to search GRAS ingredients to find data concerning an ingredient’s safety evaluation.
If you’d like to send a comment to the FDA requesting more oversight for natural flavor labels, please click here.
Published on September 22, 2022
To contact A Voice For Choice Advocacy, please email firstname.lastname@example.org.
If you would like to support the research and health education of AVFC editorial, consider making a donation today.