i- The Consumer Federation of America (CFA), a non-profit consumer advocate organization, submitted a petition to FDA on November 8, 2023, requesting that the agency amend the flavoring regulation at 21 CFR 101.22 to replace the use of “natural flavor” with “added flavor” or “added flavoring.”
- Under 21 CFR 101.22, “natural flavor” and “natural flavoring” are those flavors/flavorings derived from natural (i.e., plant or animal) sources. Specifically, the regulation defines these terms to mean “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.” Artificial flavors/flavorings are defined inversely; they are flavors which are not derived from these sources.
- The petition argues that there are often few distinctions between natural and artificial flavors, both of which are frequently highly processed. It also raises questions about the safety and healthfulness of highly processed flavors, including concerns that they may induce overeating.
- The petition is careful to note that it does not seek to erase the distinction between “artificial” and “natural flavors” and that the proposed revision would still distinguish between the two. Furthermore, a manufacturer seeking to promote the natural quality of its flavor could still use the ingredient’s common or usual name (e.g., mint extract).
Petition Requests that FDA Amend Flavoring Regulation
Tuesday, November 21, 2023
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