When PepsiCo’s Frito-Lay North America division ended 2010 with the announcement that approximately 50% of its product portfolio would now be made with all-natural ingredients, competitive food formulators likely took a step back to investigate what exactly the Plano, TX-based convenience foods giant was defining as “natural.” After all, the term remains for the most part unregulated by the US Food and Drug Administration (FDA).

Company spokesperson Aurora Gonzalez told
Baking & Snack, “At Frito-Lay, we define ‘all-natural ingredients’ as no monosodium glutamate (MSG), no artificial or synthetic ingredients, no artificial flavors and no artificial preservatives. All Frito-Lay snack chips start with all-natural corn, grains or potatoes and healthier oils. To help consumers understand all-natural ingredients, we have included a stamp on the front of packaging that includes this explanation.”

And even though FDA has never said MSG is not natural, Frito-Lay and others such as Whole Foods Market, Inc., Austin, TX, take the stance that MSG does not possess the attributes of what these businesses believe to be all-natural. “While there is some MSG that is natural, the commercial variety is not,” Ms. Gonzalez stated. “Many consumers have requested products that do not contain MSG. In our search for all-natural ingredients, we found MSG was no longer needed in many instances.”

Frito-Lay is serious about its snack food reformulating activities and is committed to the all-natural claim. “As the snack food category leader, we have insights that show consumers are seeking a wider range of products made with all-natural ingredients,” said Ann Mukherjee, senior vice-president and chief marketing officer. “Many of the unflavored snacks in our portfolio are already made with all-natural ingredients, and we’ve focused on expanding our portfolio of products with all-natural ingredients to include more of consumers’ favorite flavored products.”

Ms. Gonzalez cited data from a March 2010 consumer survey by Mintel, Chicago, IL, showing that 65% of respondents said they were “somewhat interested” or “very interested” in natural products. Further, three-fourths of respondents in the 18-to-34-year-old range said that they had an interest in all-natural products.


In December, Mintel provided the food industry with its list of predictions for the upcoming year. According to Lynn Dornblaser, director of innovation and insight at Mintel, the food industry needs to get ready for a “natural” shakedown. “While all types of natural claims have grown in importance in all regions and across all product categories, the term ‘natural’ is still ill-defined,” Ms. Dornblaser said. “Terms that are vague or not well understood will come under fire, and we are due to see an intervention of regulatory bodies.”

She also expected that as a result of the ambiguity in the term “natural,” many marketers, working to err on the side of caution, will focus on accentuating the positives of what is in a product rather than emphasizing what is not in it. In other words, phrases such as “naturally sweetened” may become more common than “contains no artificial sweeteners.”

Further supporting Ms. Dornblaser’s predictions are recent actions taken by Flowers Foods, Inc., Thomasville, GA. According to Janice Anderson, vice-president of marketing, “Most consumers today do want to know what is in the food they are buying for themselves and their families and are looking for foods that are safe and wholesome. Even so, consumer opinion on what that exactly means varies widely. Our research has shown that ‘fiber,’ ‘100% whole grain’ and ‘100% whole wheat’ top the list of product attributes consumers look for when it comes to bread. These are followed by ‘fat’ and ‘artificial preservatives, colors or flavors.’

“While we have used the ‘no artificial preservatives, colors or flavors’ descriptor for our Nature’s Own brand since its introduction in 1977, we did not use the term ‘all-natural’ until 2006, when we rolled out a number of all-natural Nature’s Own premium breads,” continued Ms. Anderson. “These were our first all-natural products. In February 2011, we will be discontinuing those all-natural varieties. We’ve found that our ‘no artificial’ position is providing consumers with what they want.”

Indeed, taking the “nothing artificial” stance is likely the most honest position when it comes to describing ingredients added to foods. After all, FDA disqualifies numerous ingredients from ever being perceived as natural by requiring that they be labeled as artificial, chemical or synthetic in the Code of Federal Regulations (CFR). This includes select colors, flavors, preservatives and sweeteners.

“Food companies are trying to compete in an unidentified world of natural, and they are looking for some guidance, any guidance,” said Theresa Cogswell, a consultant to the baked goods industry based in Olathe, KS. “Whole Foods provides that with its list of ‘unacceptable ingredients for food.’”

The list Ms. Cogswell referred to is readily accessed via www.wholefoodsmarket.com. It includes many ingredients bakers have historically used, including dough conditioners based on mono- and diglycerides; processing aids such as calcium peroxide, bleached and bromated flours; preservatives such as calcium propionate; and ingredients that prevent rancidity, notably butylated hydroxyanisole (BHA) and butylated hydroxytoluene (BHT).

Although high-fructose corn syrup (HFCS) is not on the list, many bakers have reformulated to remove it from product formulations because of negative publicity causing consumer concern.

“There are so many ‘natural’ products out there that consumers would never fathom eating, yet they find issues with HFCS, an ingredient that even FDA has stated can be used on products labeled as ‘natural,’” Ms. Cogswell said.


Most consumers have no idea the role that many ingredients play in the food supply. Ingredients such as HFCS enable wholesale bread makers to produce affordable, good-tasting products that feed the masses. Few can afford to shop Whole Foods every other day for a fresh loaf of bread that costs $3 to $5. Lower prices characterize many private label, all-natural breads, but large families still rely on the $1.50 loaf enriched with calcium, fiber, B-vitamins and often more. And to produce such breads, bakers typically rely on some of the ingredients deemed unacceptable by Whole Foods and Trader Joe’s, which uses a similar list.

When this scenario is explained to consumers, many are more understanding of why a product may contain synthetic or processed ingredients. According to the report “Messages that Matter 2010” from Kansas City, MO-based Center for Food Integrity (CFI), connecting with consumers by using a platform of shared values is critical for building trust in today’s food system. Messages and programming that demonstrate shared values align an organization or individual with the ethical expectations of consumers. They provide consumers with assurance that manufacturers are raising, growing and bringing food to market in a responsible way.

For example, according to CFI research, attitudes about nutrition issues experienced a statistically significant positive change when consumers were made aware of validated supporting information. The report stated that consumers were more likely to agree that “Food processing includes fortification, which makes it possible for both children and adults to achieve the daily recommended amounts of essential vitamins and minerals, helping them stay healthy and strong,” when they were presented with information that detailed how processing allowed foods to be fortified with vitamins and minerals and that technologies used in food processing enabled a wide variety of foods to be available throughout the year.


Ms. Cogswell said the Whole Foods list does set a precedent for “if and when FDA ever decides to lay out some ground rules for use of the term ‘natural.’ But for now, food safety is FDA’s priority and rightfully so. Defining ‘natural’ is a regulatory role, and I don’t see FDA addressing it in the near future,” she added.

However, FDA partnered with the International Food Information Council (IFIC) Foundation, Washington, DC, in 2004 to publish a brochure (revised in 2010) explaining food additives and colors. The paper stated, “Natural ingredients are derived from natural sources (e.g., soybeans and corn provide lecithin to maintain product consistency; beets provide beet powder used as food coloring). Other ingredients are not found in nature and therefore must be synthetically produced as artificial ingredients. Also, some ingredients found in nature can be manufactured artificially and produced more economically, with greater purity and more consistent quality, than their natural counterparts. For example, vitamin C or ascorbic acid may be derived from an orange or produced in a laboratory. Food ingredients are subject to the same strict safety standards regardless of whether they are naturally or artificially derived.”

Indeed, it is important to emphasize the fact that all food additives are carefully regulated by federal authorities and various international organizations to ensure that foods are safe to eat and accurately labeled. The ambiguity concerning the term “natural” is not a food safety issue.

As mentioned earlier, FDA disqualifies some ingredients — colors and flavors — from being used in foods labeled as “natural,” because the agency characterizes them as artificial or synthetic. A number of ingredients described as chemical preservatives and non-nutritive or low-calorie sweeteners are also assumed by the industry to be artificial or synthetic, but for the record, FDA does not come right out and state this. For example, its definition of chemical preservative, as it appears in 21 CFR 101.22, is ambiguous. It reads, “The term ‘chemical preservative’ means any chemical that, when added to food, tends to prevent or retard deterioration thereof but does not include common salt, sugars, vinegars, spices or oils extracted from spices; substances added to food by direct exposure thereof to wood smoke; or chemicals applied for their insecticidal or herbicidal properties.”


Only one ingredient definition allows use of the descriptor natural, and that is the category of flavors. The US definition of natural flavor (21 CFR 101.22) encompasses “the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products or fermentation products thereof, whose significant function in food is flavoring rather than nutritional.”

A fine line distinguishes when a flavor goes from being natural to artificial, because both are manufactured through the blending of chemicals. In general, if the ingredient is not directly sourced from a living system, the flavor is considered artificial.

Synthetic food colors are classified by FDA as color additives subject to certification (21 CFR 74). They are certified with an FD&C number (indicating it has been tested for safety and is approved for use in foods, drugs and cosmetics, or FD&C) and further classified as standardized dyes or lakes.

A dye is a concentrated source of color that is water soluble and oil insoluble. Dyes can take the form of a powder, granule or liquid. Lakes, on the other hand, are made by combining dyes with mineral salts to make them insoluble compounds. Thus, they are best described as providing color by dispersion. Lakes are considered to be more stable than dyes and are ideal for coloring products that either contain fat or lack sufficient moisture to dissolve dyes.

Seven dyes were initially approved under the Pure Food and Drug Act of 1906. Over time, several have been delisted and replaced. Today, there are still seven dyes, which can be combined into an infinite number of colors. There has been much debate on the safety of artificial colors and increased discussion of these controversies is driving many consumers away from artificially colored foods. For example, the Sunday, Jan. 2, front page of the Chicago Tribune carried this headline: “Are Food Dyes Worth the Risk?”

FDA designates several color additives as exempt from certification (21 CFR 73), meaning they are not synthetic FD&C; however, a number are sourced or processed in such a way that the color’s naturalness is questionable. For example, carmine, also known as cochineal extract (21 CFR 73.100) is a bright red color obtained from the carminic acid produced by some scale insects such as the cochineal. Just how natural is it to add insect extracts to cake frosting? Also, the source disqualifies it from use in foods certified kosher or halal.

Examples of colors more readily recognizable as natural are paprika or annatto, both rich in carotenoids, or orange pigments. The anthocyanin pigments from fruits and vegetables are able to provide blue, pink, red and violet hues to foods. However, it is important to emphasize that FDA does not consider any color added to a food product to be natural, no matter what the source. The exception is if the color is natural to the product itself, as when coloring cherry fruit pie filling with cherry juice. Thus, a nacho cheese tortilla chip seasoned with dehydrated cheese colored with annatto extract should not be labeled “all-natural chip.” What is acceptable is “made with all-natural ingredients” or “does not contain any artificial colors.”


“Natural” will continue to be a positive descriptor and, in some instances, a reassurance of purity. For example, some bar soaps are described as “all natural.” However, soap is probably not what you want to slice and use to make a peanut butter and jelly sandwich for your child. But it is nice to know it can still be used to wash out a sassy kid’s mouth.

In conclusion, Flowers’ Ms. Anderson said, “I believe consumers will continue to see the term ‘natural’ as a positive product benefit, but it will be just one of many descriptors they will be looking for on food packages.”