Jennifer Allen
Food Safety Attorney

Food Labeling Requirements for Natural Flavors

By Jennifer Allen
1 Comment
Jennifer Allen

As with all ingredients, natural flavors must be identified as such on your product’s ingredients panel. But under certain circumstances, they must also be identified more prominently on the principal display panel. Jennifer Allen, food attorney at Zwillinger Wulkan, explains U.S. food labeling requirements for natural flavors.

Natural flavors are ubiquitous in foods today, and chances are, at least one of the products that your company manufactures contains them. But what are they, and how should they be identified on your packaging?

Natural flavors are defined at 21 CFR 101.22(a)(3) as “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.” In short, a natural flavor is a substance the purpose of which is simply to add flavor, which is extracted from a food through one of a certain number of processes.

The astute among you may be asking yourself right now, “Why are so many consumers critical of natural flavors? From this definition, they seem pretty natural to me.” Well, consider that the above regulation applies only to the flavor. But when you take a natural flavor off the shelf to incorporate it into your product, that flavor is contained in some kind of solvent, with certain additives for functionality. The solvent and additives are not required to be in any way “natural.” This may be why some consumers are skeptical about how “natural” natural flavors really are.

Labeling Nuances

As with all ingredients, natural flavors must be identified as such on your product’s ingredients panel. If those flavors don’t make up the primary characterizing flavor of the product, but are included simply to make your product juicier, to enhance mouth-feel or to supplement the flavor imparted by the other food ingredients, then identifying them as “natural flavors” on the ingredients panel is sufficient.

But under certain circumstances, they must also be identified more prominently on the principal display panel. As the regulations explain at 21 CFR 101.22(i), if your product has a certain primary characterizing flavor (the example the regulations use is strawberry shortcake), and most or all of that characterizing flavor comes not from the food itself but from natural flavors derived from that food, then those flavors must be clearly identified. The name of the flavor must be included. It may have the word “natural” in front of it, but it must have the word “flavored” after it. So, to use the strawberry shortcake example, if your shortcake is predominantly flavored with actual strawberries, then your label would read “strawberry shortcake.” But if it is primarily or solely flavored by natural flavor derived from strawberries, then it must be labeled: “natural strawberry flavored shortcake,” or “strawberry flavored shortcake.

What if you are flavoring your product with natural flavors that are not derived from the food that is the characterizing flavor? For example, what if your product is a lemon pie, but you flavor it only with natural flavors derived from limes? In that case, you must either include by the product name the identity of the actual flavor (for example, “with natural lime flavor”), or you must identify it as being artificially flavored. You read that correctly. Even if you are using a natural flavor, if it isn’t from the food that is the characterizing ingredient in your product, then it is considered an artificial flavor. What about a lemon pie flavored with natural lemon flavor but also with natural lime flavor. In that case, your label would include the words “natural lemon flavor, with other natural flavors.”

As a rule of thumb, if your product’s principal display panel contains the name of a food item, or a picture of a piece of fruit or other food item that the consumer would understand to be the primary recognizable flavor in the product, but the product does not in fact contain that fruit or other food item, or is predominantly flavored with natural flavors, then you must comply with the labeling requirements above. But if your product is predominantly flavored by the food item itself, with the natural flavors simply enhancing the flavor or serving a secondary flavoring function, then you need only identify the presence of natural flavors in the ingredients panel.


About The Author

Jennifer Allen


  1. Karen HInes

    HI Jennifer,
    What if you are using oleoresin? I put spice extract in my ingredient statement and unless it is Paprika, Turmeric, or Annatto, I don’t add what spice it is from. Do I need to put the spice flavor also?
    thank you
    Karen Hines

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