# Lentis/Marketing of Natural Foods
## Introduction

Recent years have seen an increasing trend in natural and organic food consumption. Many consumers perceive natural and organic food as healthy and beneficial to the environment, but do not fully understand regulatory differences between the two. In the United States, consumers have spent more than $40 billion annually on natural-labeled foods. 51% of Americans search for all-natural products when shopping. However, consumers are confused by the term's meaning and only 47% view the claim as trustworthy. Recent attempts to establish a standard in the absence of the government regulation, concludes that natural food labels are more likely to be abandoned by food manufacturers than it is to be defined in a uniform and enforceable manner. Without proper definitions and regulations, producers can continue mislabeling natural foods and profiting from them.

## Regulatory Standards

The three primary regulators of organic and natural foods are FDA, USDA, and Congress. FDA is responsible for advancing the public health. They provide accurate, science-based information for foods to maintain and improve health. They designate nutrition labels and regulate majority of foods. USDA mainly oversees meat, poultry, and eggs. They are responsible for defining organic. Congress passes legislation that affects how FDA and USDA can regulate food labeling.

### Natural Food Labeling
##### FDA Regulations

FDA does not regulate "all natural" foods labels. The FDA has considered the term "natural" to mean that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food. This policy was not intended to address food production, manufacturing, or processing methods. For example, foods containing genetically engineered ingredients, foods treated with pesticides, and foods containing high fructose corn syrup all may be labeled as "natural". It also doesn’t consider whether a food has health or nutrition benefits. By definition, food products containing ingredients produced using genetic engineering or foods containing high fructose corn syrup may be labeled as "natural". The FDA has historically not defined the term “natural” due to difficulty in doing so, as most food “has probably been processed and is no longer the product of the earth.”

#### High Fructose Corn Syrup

Products containing high fructose corn syrup may still market themselves as natural because high fructose corn syrup is derived from corn which is a natural ingredient, and no synthetic agents are in contact during manufacturing. The FDA explicitly stated that it would not restrict the use of the term "natural" except on foods that contain added color, synthetic substances, and flavors.
Genetically Modified Foods
Genetically modified (GMO) foods have often come under backlash by consumers because of the fear they have towards the label. However, there is opposition as to the fear surrounding this label because most modern crops have deviated far from their original wild variety's genetic makeup through GMO/GE technology or conventional breeding techniques.

### Organic Food Labeling

USDA verifies foods as USDA organic. Organic operations must demonstrate that they are protecting natural resources, conserving biodiversity, and using only approved substances. The specific regulations can be found here. "Organic” is a labeling term for food or agricultural products (“food, feed, or fiber”) that have been produced according to USDA organic regulations, which define standards that “integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” USDA standards recognize four types of organic production:
* Crops: “Plants that are grown to be harvested as food, livestock feed, or fiber used to add nutrients to the field.”
* Livestock: “Animals that can be used in the production of food, fiber, or feed.”
* Processed/multi-ingredient products: “Items that have been handled and packaged (e.g. chopped carrots) or combined, processed, and packaged (e.g. bread or soup).”
* Wild crops: “Plants from a growing site that is not cultivated.”

### Congress

The U.S. Congress is responsible for making laws related to natural foods, powers of the food industry, and role of the FDA in defining standards of food safety. For example, in July 2016, the Congress passed the National Bioengineered Food Disclosure Standard which required labels to identify genetically engineered food. While some labels were mandated, other foods were labeled by the manufacturers. This can be misleading for consumers. Similarly, in 1990, the Congress passed the Organic Foods Production Act to regulate and define organic food. However, organic labels were accepted in the range from 20% to 100% organically grown ingredients. With a loose definition, even the most sophisticated consumers were unsure of the exact definition of organic foods. It was only after years of various laws that properly defined and regulated organic foods. Natural foods will also most likely suffer this delay, especially due to FDA's refusal in defining the term "natural".

## Marketing Strategies

In the interest of generating revenues, producers have taken to natural food marketing practices that some have characterized as misleading, with a number of class action lawsuits seeking to end these tactics.

### Pricing Origins

The markup on natural foods can be traced to more justifiably expensive organic foods.

#### Organic Foods

The price premium of organic foods over conventional foods is explained by the cost of supporting investments. Strict regulations require that producers follow additional procedures. Registration and certification carries an upfront cost; land must comply with minimum organic standards for three years, an expensive process given that food produced under such standards cannot yet be sold as organic during this period. During certified production, if a requirement is violated, such as by cross-contamination with non-organic products or other means, the product is rendered legally non-organic and efforts involved are wasted. This risk scales with larger production batches, and so producers must take precautions to avoid it.
Despite these difficulties, producers have found success in marketing the benefits of organic foods. In 2016, sales saw 7.1% growth amidst decline in non-organic sales.

#### Natural-Organic Connection

For producers, natural foods represent an ideal middle ground between organic and non-organic foods, owing to reduced costs and favorable public perception. Looser regulations for natural foods imply fewer investments necessary for government approval. The lack of minimum land compliance time alone indicates a much lower barrier to entry. In addition, studies found that consumers generally regard natural labeled foods nearly as highly as organic labeled foods despite significant regulatory differences. The Hartman Group observed that "organic" carries a connotation of lacking undesirable ingredients, while "natural" evokes more positive associations. Prices for natural foods in America were found to be around 15% lower than organic foods, but still higher than conventional foods.
Because natural foods can be priced nearly as high as organic foods while costing disproportionately less to produce, they represent a strong value proposition for producers.

### Strategies

Lax regulation enables not only lower production costs, but also greater marketing liberties by exploiting technicalities and consumer preconceptions. For example, a consumer could be lead to believe that a hot dog labeled "contains 100% all-natural beef" contains only beef, but may in fact comprise other meats as well - it's only guaranteed that the beef used was raised using natural methods. Additionally, this consumer may incorrectly assume improved environmental practices and animal welfare. Issues also stem from the fact that "natural" can be used as an adjective outside of regulated contexts. Claims to nature such as "contains natural goodness" are essentially meaningless, and serve only to further cloud consumer understanding of this term.

## Other Common Marketing Buzzwords

The FDA has many buzzwords other than “natural” that have a large difference between customers’ expectations/standards and the actual regulations surrounding marketers’ usage of that word-- we will call this difference the “marketing divergence”. Marketers exploit this divergence to sell products to unsuspecting consumers. Some examples of buzzwords that have a high marketing divergence are “healthy”, “fresh”, “fat-free”, and “zero-calorie”.

### Healthy

According to the FDA, a food can be marketed as “healthy” if it is “useful in creating a diet that is consistent with dietary recommendations if the food meets the conditions for total fat, saturated fat, cholesterol, and other nutrients.” However, these criteria themselves are vague and the FDA’s proposed dietary guidelines attempt to act as a one-size-fits-all when diet is a highly personalized matter. It is also assumed by the FDA that consumers are looking for strictly nutritional constraints.
In a study on 1,290 food consumers it was found that many consumers associate “healthy” with non-nutritional requirements. In a survey ranking 13 potential characteristics linked to eating “healthy”, usage of hormones/antibiotics, pesticide residues, preservatives, and GMOs were all ranked higher in association over nutritional constraints like protein, vitamin, and fiber contents.Although the FDA standards are based on scientific research, it is imperative to prioritize how consumers interpret the term to ensure “healthy” is behaviorally relevant.
Consumer behavior goes just beyond making a decision to buy one product over a competitor’s-- it extends into eating behavior. In the same study, approximately 40% of respondents interpreted that the “healthy” label indicated they should increase consumption of the product, 15% interpreted they could eat all they wanted of it, and 34.7% said the label meant nothing to them.
In 2016, the FDA began the process to redefine “healthy”, as of 2021 they still have not come to a conclusion.
| | Individual Food | Seafood/Game Meat | Meal/Main Dish |
| Total Fat | low fat | < 5 g fat /RACC & /100g | low fat |
| Saturated Fat | low sat fat | < 2 g sat fat /RACC & /100g | low sat fat |
| Sodium | ≤ 480 mg /RACC and / l.s.; or /50 g, if RACC is small | ≤ 480 mg /RACC and /l.s.; or /50 g, if RACC is small | ≤ 600 mg /l.s. |
| Cholesterol | ≤ disclosure level | < 95 mg /RACC & / 100 g | ≤ 90 mg /l.s. |
| Beneficial Nutrients | Contains at least 10% of DV / RACC for vitamins A, C, calcium, iron, protein, or fiber except: raw fruits and vegetables; or a single ingredient or mixture of frozen or canned fruits and vegetables (may include ingredients whose addition does not change the nutrient profile of the fruit or vegetable); enriched cereal-grain products that conform to a standard of identity in 21 CFR 136, 137, or 139 | Contains at least 10% of DV /RACC for vitamins A, C, calcium, iron, protein, or fiber | Contains at least 10% of the DV /l.s. of two nutrients (for a main dish product) or of three nutrients (for a meal product) of vit. A, vit. C, calcium, iron, protein, or fiber. |
| Fortification | Per 21 CFR 104.20 | Per 21 CFR 104.20 P | Per 21 CFR 104.20 P |
| Note: l.s. = labeled serving; RACC = R eference Amount Customarily Consumed per Eating Occasion; small RA CC = 30 g or less, or 2 tablespoons or less ||||

### Fresh

The FDA defines fresh foods to be unprocessed and in a raw state. However, there are certain exceptions including specific waxes/coatings, pesticides, chlorine/acid washes, and radiation treatments.
While consumers may have an idealistic “farm to table” image when they see the fresh label, this can also come at risk of food-borne illnesses from lack of precaution & processing.
For example, in 2006 an E.coli outbreak in spinach caused a large-scale reevaluation of farming practices related to leafy greens. As a result, the Food Safety Leadership Council investigated best practices in leafy green farming and introduced the California Leafy Greens Handler Marketing Agreement (LGMA).
However, when writing the LGMA, the council found it difficult to separate best farm practices from methods to control crop-specific risks. Specifically, the LGMA provides instructions water quality, water testing, worker hygiene and sanitation, and safe separation distances between crop production and other specified land uses, etc.
While the FDA has made extensive efforts to rectify the 2006 E.coli spinach scare, this level of effort is not actively being applied to all industries that are able to use the “fresh” label.

### Fat-Free & Zero Calorie

When it comes to labeling as “free” or “zero” of a substance, the FDA generally likes to use the round-down rule. For example, products with less than 0.5 g of fat per serving can be rounded down and labeled as “fat-free”. Similarly, products with less than 5 calories per serving can be rounded down and marketed as “zero calorie.” The FDA reasons that these thresholds present a “negligible amount”, thus enabling marketers to present such claims.
This can present a similar issue to when products are labeled as “healthy” where consumers falsely assume they can consume as much of the product as they’d like. This results in overconsumption that can quickly increase a consumer’s fat & caloric intake beyond a “negligible amount”.

## Consumer Perspective

Many consumers remain unaware that the term "natural" is currently unregulated and undefined in the food industry. Due to an altruistic attitude towards natural food consumption, consumers believe natural foods are more virtuous. Consumers expect that a "natural" label means that the processed food does not contain any artificial ingredients and are pure, clean, and healthy.

### Perceived Benefits

Despite higher prices, some consumers choose specially labeled foods for certain perceived benefits.

#### Quality

Consumers believe that cost is linked to food quality. Price tags seemed to awaken expectations that were sufficient to influence the resulting overall taste experience similar to a Placebo Effect. Therefore, food that cost more such as natural foods result in a more pure and rich taste.

#### Health

Consumers who consider future consequences are more likely to consume organic food.
For example, Kiczorowska et. al. surveyed a group of pregnant women and found that a majority purchase organic food infrequently. "The main motive behind buying organic food was their wish to take special care of their health during the pregnancy period and the need to take care of the family." However, they found a majority to also lack sufficient knowledge about what organic labeling entails, with 60% defining it as "natural."

#### Environmental

Consumers believe that organic foods are better for the environment because synthetic pesticides are not used. However, to expand on that understanding, pesticides that are not approved for use by the USDA cannot be used for production of “organically grown” foods, meaning all types of synthetic pesticides cannot be used in organic farming practices as they are not included in the approved list of pesticides. The list only includes pesticides that are naturally-derived.
Conventional farming not only destroys top soils and pollutes our waters, but it also emits more potent greenhouse gases such as nitrous oxide. Organic farming, on the other hand, utilizes natural ways of farming (as shown in the table below) and provides benefits to soil health and quality. Lori et al. stated that organic farming has 32% to 84% greater microbial biomass carbon, nitrogen, and fatty-acids than conventional farming. Rich microbial biomass is necessary for the health and quality of soil. Despite organic farming having 20% less yield than conventional farming, it is more beneficial for the environment.
Organic vs Conventional Farming :
| Organic Farming | Conventional Farming |
| Grown with natural fertilizers (manure,compost) | Grown with synthetic or chemical fertilizers |
| Weeds are controlled naturally (crop rotation, hand weeding, and mulching) | Weeds are controlled with chemical herbicides |
| Pests are controlled using natural methods and naturally-derived pesticides | Pests are controlled with synthetic pesticides |
Synthetic pesticides, which conventional farming heavily depends on, raise a great number of negative environmental effects. Synthetic pesticides may be effective in eliminating targeted pests, but the use of synthetic pesticides may also result in several “unwanted side effects”, negatively affecting the population of the non-target species like the humans as well as the surrounding environment. Consumers evaluate the risks of pesticide use highly and do not perceive the benefits from pesticides as experts do, but there exists a lack of awareness of the effects of pesticides. This can partly be understood given that the effects of “pesticide use are indirect and not immediately apparent to the average consumer.”

### Genetically Modified Foods

Although the USDA’s definition of organic excludes genetically modified (GMO) foods, we can learn about customer’s wants from the controversy surrounding GMO foods. GMO foods have often come under backlash by consumers for a variety of fears despite research backing their safety. However, the question arises if this fear is valid as most modern crops have already deviated far from their original wild variety's genetic makeup through conventional breeding techniques.
For example, common crops such as corn, rice, and apples have deviated from their wild varieties for taste, aesthetics, nutrition, etc. through long-term breeding practices from farmers. Crops are genetically modified for similar reasons, however, the concern regarding their circulation was found to be more psychosocial than medical according to the AAGE (Annals of Agricultural and Environmental Medicine).
In a study conducted on 500 secondary school students, major concerns found related to GMO foods were the risk of development of new health disorders in humans and a higher risk of unfavorable genetic changes in humans. These fears can be linked to a lack of elementary knowledge on the subject and distrust in media & journals. Amongst the students surveyed, 81.4% self-assessed themself as “unlikely I know” or “I know very little about.” However, despite this self-assessment, 64.1% of all respondents found research detailing the benefits of GMO crops untrustworthy.
We can draw the conclusion that along with research to prove the safety of modern farming practices, efforts must be made to convince the public of its validity. If not, the advancements being made will result in wasted food and persisting world hunger.

## Consumer Pushback on "Natural" Food

Certain consumer movements claim that the FDA should create a formal definition of “natural” supported by scientific backing to prevent misleading or ambiguous usage. They cite that the FDA and USDA are statutorily mandated to protect consumer interests in prohibiting false and misleading labeling, but both agencies have refused to formally define the term "natural". FDA also refuses to determine if GMO foods should be permitted to be labeled as "natural". Others assert that if the FDA cannot settle on a definition and regulatory mandate for "natural," then companies should be barred from using the term altogether. Consumers have taken it upon themselves to take action against the use of "natural" in courts or petitions if they cannot rely on the oversight of regulatory agencies to provide food manufacturers with clear and concise regulations.

### TakePart

In 2015, a TakePart petition titled “Stop Confusing Consumers: Ban the ‘Natural’ Label” received over 33,000 signatures. In it, respondents urged both the FDA and the USDA to ban and/or restrict its use on food products.

### Court Action

Consumers hope to change the natural foods landscape by increasing the literacy about natural foods in a tangible way. However, results from court action against corporations have been mixed. Several courts have dismissed claims or "stayed the case to seek clarification from the FDA, even though the Agency repeatedly declines to intervene or further define the term". However, there have been some notable wins for consumers. In 2008, Williams vs Gerber case found that Gerber's fruit snacks which are marketed as natural likely deceived consumers by having pictures of different fruits on their packaging. This could potentially lead consumers to believe that the product contain those natural fruits and flavors.

## FDA Response
### Request for Information (RFI)

On November 10th 2015, the FDA requested public comments on the use of the term “natural” on food labels in direct response to consumer requests. This action was spurred by both Citizen Petitions, a process defined by the FDA for both individuals and organizations to request changes in policy, and Federal Court requests for clarification on relevant litigation. Three Citizen Petitions requesting the agency define the word were submitted by: the Grocery Manufacturers Association, a trade association for consumer packaged goods, the Sugar Association, a trade association for the sugar industry, and Sara Lee Corp, a consumer goods company. One petition by the Consumer Union, a consumer advocacy nonprofit, requested a ban on the use of the word natural.

### Response to the RFI

The FDA was seeking opinions on whether they should regulate the word natural, how they should do so, and what should be considered appropriate use of the term. This public comment period closed on May 10th, 2016, having received about 7,680 comments from individuals, interest groups, and impacted industries. This request for information was popular enough to warrant an extension on the response period. The responses were overall split evenly in between support and opposition or ambivalence in defining the term. While most comments supported inclusion of the elements already included in the definition of natural, there was little consensus on topics not addressed such as production, processing, and alignment with the organic/healthy labels.

### Further Action

The FDA concluded that “additional information and analysis was needed”, and performed additional consumer research on the subject since the RFI, however no proposal for a new definition of “natural” was filed. The FDA established the Nutrition Innovation Strategy (NIS) on March 29th, 2018, with “Modernizing Claims” being one of the key elements of the strategy. They stated they have intentions to update the criteria for the “healthy” claim, with work on this rule also being mentioned in a May 6th, 2021 procedural notice into research on the claim. This strategy also acknowledged the requests for clarity in the usage of “natural”, though there is no public update as to whether there will be an update to the criteria.
The Food Labeling Modernization Bills, introduced in 2013, 2015, 2018, and again in 2021 compel the FDA to define both “natural” and “healthy” within a certain timeframe amongst other requirements intended to improve food labels. This bill was supported by many consumer advocacy groups such as: Center for Science in the Public Interest, Consumer Reports, Environmental Working Group, Gluten Free Watchdog, amongst others.

## Conclusion

Viewed through the lens of balances of power, natural-labeled foods skew the consumer-producer relationship towards the latter participant. While consumers are paying nearly as much for natural labels as organic labels, the benefit received is less than expected hence creating a marketing divergence. Lax regulations and public misconceptions allow producers to increase profits. However, this is not an isolated case as seen by other high marketing divergence buzzwords like “healthy”, “fresh”, “fat-free”, and “zero-calorie.”
Growing numbers of opposing litigation point to growing awareness of these marketing tactics and return of consumer power. The potential redefinition of "healthy" as part of the NIS may shift this balance of power and spur action on other claims such as "natural." The cumulative result of consumer advocacy and regulatory agency response still remains to be seen.
Further work may help shed light on additional government-regulated marketing techniques, identify more research that focuses solely on natural foods, expand on consumer advocacy strategies, and keep tabs on current legislation and regulatory measures.

## References

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* 1 2 3 FDA. (2015). Use of the term natural on food labeling. U.S. Food and Drug Administration. https://www.fda.gov/food/food-labeling-nutrition/use-term-natural-food-labeling.
* ↑ FDA. (2015, November 12). Use of the Term “Natural” in the Labeling of Human Food Products; Request for Information and Comments. Federal Register. Retrieved December 9, 2021, from https://www.federalregister.gov/documents/2015/11/12/2015-28779/use-of-the-term-natural-in-the-labeling-of-human-food-products-request-for-information-and-comments.
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* ↑ FDA. (2015, December 28). Use of the Term “Natural” in the Labeling of Human Food Products; Request for Information and Comments; Extension of Comment Period. Federal Register. Retrieved December 9, 2021, from https://www.federalregister.gov/documents/2015/12/28/2015-32471/use-of-the-term-natural-in-the-labeling-of-human-food-products-request-for-information-and-comments.
* ↑ Hansen, A. P. (2019, September 25). Use of the Term “Natural” in Food Labeling FDA’s Perspective [PowerPoint slides]. Institute for Food Safety and Health, Illinois Institute of Technology https://www.ifsh.iit.edu/sites/ifsh/files/departments/Use%20of%20the%20term%20Natural%20in%20food%20labeling%2C%20PHansenFINAL.pdf
* ↑ FDA. (2021, June 9). FDA Nutrition Innovation Strategy. U.S. Food and Drug Administration. Retrieved December 9, 2021, from https://www.fda.gov/food/food-labeling-nutrition/fda-nutrition-innovation-strategy.
* ↑ Moore, K. F. R. (2021, August 20). It’s Groundhog Day for Food Labeling, Again: The Food Labeling Modernization Act is Back [web log]. Retrieved December 9, 2021, from https://www.thefdalawblog.com/2021/08/its-groundhog-day-for-food-labeling-again-the-food-labeling-modernization-act-is-back/.
* ↑ Food Label Modernization Act, House Committee on Energy and Commerce (2021). bill. Retrieved December 9, 2021, from https://energycommerce.house.gov/sites/democrats.energycommerce.house.gov/files/documents/Food%20Labeling%20Modernization%20Act%20Bill%20Text.pdf.
* ↑ House Committee on Energy & Commerce. (2021, August 4). Pallone, Delauro, Blumenthal, Whitehouse, and Markey Introduce Food Labeling Modernization Act. Committee on Energy & Commerce . Retrieved December 9, 2021, from https://energycommerce.house.gov/newsroom/press-releases/pallone-delauro-blumenthal-whitehouse-and-markey-introduce-food-labeling.