The US Food and Drug Administration (FDA) is seeking comments on the use of the term ‘natural’ for the labeling of human food products.

The unexpected move by the US regulatory agency comes after many years of avoiding the growing issue and more recently since 2014, declining to act in natural claims civil cases that included whether GMO foods should be classified as being part of all-natural products.

The FDA, which originally announced the labelling action in early November, issued a notice in December that it was, “announcing the establishment of a docket to receive information and comments on the use of the term “natural” in the labeling of human food products, including foods that are genetically engineered or contain ingredients produced through the use of genetic engineering”.

“We are taking this action in part because we received three citizen petitions asking that we define the term “natural” for use in food labeling and one citizen petition asking that we prohibit the term “natural” on food labels.

“We also note that some Federal courts, as a result of litigation between private parties, have requested administrative determinations from FDA regarding whether food products containing ingredients produced using genetic engineering or foods containing high fructose corn syrup may be labeled as ‘natural.’”

The FDA added that it is working with the United States Department of Agriculture (USDA) Agricultural Marketing Service and Food Safety and Inspection Service also to examine the use of the term “natural” in meat, poultry, and egg products, and are considering areas for coordination between FDA and USDA.

It has invited interested persons to comment on the use of the term “natural” in the labeling of human food products, including when, if ever, the use of the term is false or misleading and is particularly interested in responses to questions that include:

*Should we define, through rulemaking, the term “natural?” Why or why not?

*Should we prohibit the term “natural” in food labeling? Why or why not?

* If we define the term “natural,” what types of food should be allowed to bear the term “natural?”

*Should only raw agricultural commodities be able to bear the term, why or why not?

*Should only single ingredient foods, e.g., bottled water or bagged spinach, be able to bear the term? Why or why not?

*If multi-ingredient foods should be able to bear the term, what type(s) of ingredients would disqualify the food from bearing the term? Please explain why such disqualification would be warranted.
The FDA is also interested in any data or other information to suggest that consumers associate, confuse, or compare the term “natural” with “organic” (the USDA administers the National Organic Program).

“We are interested in data and other information about consumers’ understanding of foods labeled “natural” versus “organic.” Is the term “natural” on food labels perceived by consumers the same way as “organic?” Or is “natural” perceived to be “better” (or not as good as) “organic?”