Main Street Project


What’s in a Label, part 1

Food labels are currently being scrutinized on the federal level. Changes under consideration could significantly increase or decrease transparency for consumers. They could also significantly change the way sustainable, regenerative food producers like Main Street Project can label their products for sale, and how much meaning those labels will carry.

Depending on your background, you may have a positive, negative, or ambivalent reaction to the “natural” description on packaged food. Each of those reactions is equally valid, because the label itself has essentially no meaning. You’d be just as likely to pick a healthy product if you restricted yourself to a random color of packaging.

But since it is used, boldly and pervasively, more than half of Americans favor the natural label over any other on food products[i] and an estimated two-thirds believe it means “that a processed food has no artificial ingredients, pesticides or genetically modified organisms (GMOs).”[ii]  The FDA has had a laissez-faire attitude towards the term since the administration’s inception, and no wonder, really. If we take the most appropriate dictionary definition, that is, “formed by nature … not manufactured or processed … growing of itself, self-sown,” then almost no food sold anywhere is natural. If we choose another description, “having a real or physical existence … pertaining to physical things…” then everything is. But federal guidelines aren’t supposed to be instinctive or dictionary-appropriate, they’re supposed to be clear, reasoned, and defensible. Instead, here’s what we have from the FDA:

From a food science perspective, it is difficult to define a food product that is ‘natural’ because the food has probably been processed and is no longer the product of the earth. That said, FDA has not developed a definition for use of the term natural or its derivatives.

Then why permit such a meaningless label at all? Well, there’s the little issue of the First Amendment. And the other little issue of the $40 billion in “natural” foods sold every year. But pressure from all sides is forcing the FDA to take a stand. The Grocery Manufacturers Association filed a so-called “citizens petition” with the FDA to explicitly allow foods that are “derived from biotechnology” (genetically modified) to be labelled “natural.” On the other end of the spectrum, the advocacy arm of Consumer Reports formally requested that the “natural” label be removed from food entirely, since it is both meaningless and misleading. In addition, three federal district courts have asked the FDA to give them concrete guidance in making decisions about the use of the label. All of this has led to a public comment period, open now.

You may be skeptical about the FDA’s intentions, but they put together a pretty impressive and thorough collection of questions to guide commenters, and any solicitation of public feedback, in my eyes, is a good one. (Look at what John Oliver’s call for comments did for Net Neutrality.) Here’s a sample:

  • Should we define, through rulemaking, the term “natural?”
  • Should we prohibit the term “natural” in food labeling?
  • If we define the term “natural,” what types of food should be allowed to bear the term?
  • Should only raw agricultural commodities be able to bear the term?
  • If multi-ingredient foods should be able to bear the term, what type(s) of ingredients would disqualify the food from bearing the term? …why?
  • If we were to […] establish a regulatory definition for “natural,” should certain production practices used in agriculture, for example, genetic engineering, mutagenesis, hybridization, the use of pesticides, or animal husbandry practices, be a factor in defining “natural?”
  • We are interested in any data or other information to suggest that consumers associate, confuse, or compare the term “natural” with “healthy.”

Concerned eaters can take a moment during the dark days of winter to shed a little light on this issue at!documentDetail;D=FDA-2014-N-1207-0001.

Part 2: Food Labels vs. States’ Rights!

[i] p.582     [ii]

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