# Presentation: 495069

## Public Meeting on Product Labeling:  Definition of the Voluntary Claim “Natural” on Meat and Poultry Product LabelsA History of the Policy on “Natural” Claims December 12, 2006

**Dr. Robert C. Post, Director**
**Labeling and Consumer Protection Staff **

## FSIS Prior Labeling Approval System

- Applies misbranding provisions of laws and labeling requirements in regulations daily
- Manufacturers must submit all labels with claims and special statements for evaluation and approval by Labeling and Consumer Protection Staff before use in commerce

## Labeling Policy Guidance 

- Interpretations of regulations
- Helpful and transparent way to set out the factors considered in making judgments about labeling
- Policy guides respond to trends in marketing products with features, statements, and claims not explicitly addressed by regulations
- Policy Memos/FSIS Food Standards and Labeling Policy Book = primary vehicles

## Policy Memo 055 on “Natural” Claims (November 22, 1982) 

- Intended as guide to manufacturers for developing labeling bearing “natural” claims that FSIS would likely find truthful and not misleading
- Conditions were specified for using the claim

## Factors for Considering “Natural” Claims 

- Product does not contain artificial flavor, coloring ingredient, or chemical preservative, or any other artificial or synthetic ingredient, *and*
- Product and its ingredients are not more than minimally processed

## Factors for Considering “Natural” Claims

- Minimal processing:
- traditional processes used to make food edible, preserve it, or make safe, *or*
- physical processes that do not fundamentally alter the raw product or that only separate a whole food into component parts, e.g., ground beef

## Factors for Considering “Natural” Claims

- Relatively severe processes, e.g., acid hydrolysis, are more than minimal
- Exception is that case-by-case statements such as “all natural ingredients except for hydrolyzed milk protein” may be approved

## “Natural” linked to brief statement of meaning on label, e.g., “no more than minimally processed and contains no artificial ingredients”

“All natural ingredients” claim may be used if applicable 

- “All natural ingredients” claim may be used if applicable

- Factors for Considering “Natural” Claims

## “Natural” Policy 

- Modified on occasion to be consistent with prevailing policies, to reflect case-by-case decisions, and to update regulatory references
- Modified in August 2005 to record case-by-case decisions made in approving labels for “natural” products containing sugar, sodium lactate, and natural flavors

## Growing Interest in Marketing “Natural” Meat and Poultry Products 

- Requests for “natural” on labels of products resulting from processes and including ingredients not found in “Grandma’s kitchen”
- Significant disagreement about aspects of the 2005 policy modification

## Petition received to codify policy 

Information also raises questions about when, and if, a food containing a multi-purpose ingredient, e.g., sodium lactate, or resulting from a new processing technique could be fairly characterized as “natural”

- Information also raises questions about when, and if, a food containing a multi-purpose ingredient, e.g., sodium lactate, or resulting from a new processing technique could be fairly characterized as “natural”

- Growing Interest in Marketing “Natural” Meat and Poultry Products

## Questions That Help Focus Rulemaking 

- 	Is it reasonable to include as part of the definition of “natural” a stipulation that products can be no more than minimally processed to be eligible to bear the claim?

## Questions That Help Focus Rulemaking

-    Are there any accommodations necessary to allow for certain operations because food processing and packaging techniques for enhancing safety may disqualify a product as “natural?”

## Questions That Help Focus Rulemaking

- 	What are the implications and conflicts that exist with regard to using current and new food processing methods and certain classes of ingredients, and the meaning of the claim “natural” on the labels of meat and poultry products?

## Questions That Help Focus Rulemaking

- 	Are there available data from consumer studies about what the claim “natural” means on the labels of food products, including meat and poultry products?
-      What do consumers think that the terms “minimal processing,” “artificial and synthetic,” and “preservatives” mean?

## Questions That Help Focus Rulemaking

- 	Do food safety and consumer protection benefits of using what historically may have been considered more than minimal processing techniques and antimicrobial agents outweigh conflicts with the meaning of “natural?”

## Rulemaking 

- The content of the rulemaking will derive from our consideration of what we hear and receive in comments
- While we move through stages, we will evaluate “natural” labeling claims on case-by-case basis using the factors that are set in policy