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Use of the Term ”Natural” in the Labeling of Human Food Products
Comment Tracking Number: 1k0-8pj9‐edsz
Agency: Food and Drug Administration (FDA)
Document Type: Nonrulemaking
Title: Use of the Term ”Natural” in the Labeling of Human Food Products; Request for Information and Comments; Extension of Comment Period
Document ID: FDA‐2014‐N‐1207‐1827
COMMENT FROM EVOLVA
- The term “natural” should be restricted to products obtained directly from the wild
- More precisely defined terms like ‘organic’, ‘sustainable’ or ‘biological’ will inform the consumer in a clearer manner
- The alternative to consider is a 1‐10 scale that captures the spectrum of naturalness
Using “natural” as a marketing proposition is misleading
Consumers tend to equate the word ”natural” with “good for you”, which is why the word is used so broadly in advertising, despite the fact that whether something is “natural” has nothing to do with whether it is, in fact, good or bad for you. Ebola, smallpox and ricin are completely natural, but (quite) bad for you. Bicycles, the top-selling prescription drug Aripiprazole, and running shoes are completely artificial, but good for you.
Consumers are hard pressed to define where the line should be drawn between “natural” and artificial, which suggests that there is a massive amount of confusion, and the politics today that surround the word “natural” only further confuses the matter. When the average person is forced to name a few examples of “natural” they very quickly realize that something they first thought was ”natural” is actually not so much.
Consumer confusion about “natural” is being exploited by those on both sides of this debate.
We believe, therefore, that the use of the word “natural” should be restricted to protect consumers from being sold false benefits.
Use of the word “natural” should be restricted to “wild” products
At its core, “natural” means something that occurs in nature, in contrast to something that does not, i.e. that was “man-‐made” (or rather made by humanity). Whether something was made by humanity a long time ago (the Pyramids or wheat) or very recently (an iPhone or a genetically engineered salmon) does not affect this status.
In principle, anything made by a human is not natural. Staples grains like wheat and haloed greens like kale are just two of many examples of plants created through breeding. Other examples include modern apples, agriculture (organic or conventional), yoghurt, wine, bottled or purified water. Almost everything we consume today only exists through the “hand of man”, and hence is not natural.
The term ”natural” should thus be restricted to products that have not been touched by the “hand of man”. Water from mountain streams, wild mushrooms, wild blueberries, wild oysters, shellfish, salt, etc. The fact many of these things can be dangerous does not detract from their naturalness. So, perhaps there needs to be a disclaimer that ”use of the term ‘natural’ does not imply any health benefit”.
It could then be preferable to use better defined (or definable), and less loaded, words like organic, sustainable, biological, etc. to convey useful information to consumers.
Alternatively, define “natural” as a spectrum
The above approach would relegate the word ”natural” to a very few products. And maybe this is how it should be. One alternative could be to define a spectrum that quantifies the naturalness of a product. Because pretty much all food today combines elements from nature and elements from the “hand of man”, such a spectrum would be widely applicable.
For example (and this is indicative only), foods could be scored on a 10‐0 spectrum (10 = fully natural, 0 = completely non‐natural):
10 Wild‐picked mushroom
9 Gene‐altered (whether breeding or GM) salmon, caught from wild, or a ”heritage” crop produced via agriculture
8 Gene‐altered (whether breeding or GM) corn, produced via agriculture
6 Bread (bread does not occur in nature, but the feedstocks for making bread are from agriculture, and the fermentation process for making bread occurs in nature)
5 Whiskey (distillation is not natural, but the feedstock is agriculture)
3 Artificial cheese
2 Vanillin made using synthetic chemistry from petrochemicals (ingredient occurs in nature, production method and feedstock do not)
1 Aspartame (ingredient does not occur in nature, some elements of production process do)
0 Sucralose (neither ingredient nor production method occurs in nature)
Note: Because this is purely indicative, we did not list every number. Composite products like, say, an Oreo cookie would be given a value based on the weighted average of its ingredients.
Evolva is a small functional ingredients producer, making (by fermentation) ingredients that occur in nature, but where the ”natural” supply chain has issues (animal or plant is too rare, or makes too little of the ingredient to be economic, etc.).
We “brew” these ingredients using genetically modified baker’s yeast, just like we were making beer. The finished ingredient is identical to the “natural” ingredient and contains no recombinant material (neither DNA nor protein). We sell our ingredients to food, personal care and similar.