Eat Natural? Not According to the Food Standards Agency

The term 'Natural' is now used so loosely by the food industry that it can barely be taken to mean anything, except perhaps to differentiate food from, say, stationery or garden furniture. I contacted the FSA recently (an independent UK Government department set up to protect the public's health and consumer interests in relation to food) to ask whether there were any laws governing the use of the term when used to describe food. They told me:

There is no legal definition of the word "natural" in food product labelling, however consumers are protected by the legal provisions outlawing false or misleading labelling in the Food Safety Act 1990 (as amended), the Trade Descriptions Act 1968 and The General Food Regulations 2004. The Food Standards Agency has also published the guidance 'Criteria for the use of the terms fresh, pure, natural etc in food labelling', to indicate using terms such as “natural” are likely to be misleading.

[The emphasis and hyperlink are my additions.]

Curious about these 'Criteria', I read the document and was pleased to discover that ingredients like sugar are, by any reasonable interpretation of the guidelines, not natural. This put a few manufacturers that I know of in breach of these guidelines.

Here is my open letter to the first of these, the Eat Natural company. Over the next few days I will be contacting them to invite comment.

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Dear Sirs,

Your Eat Natural bars contain ingredients which are not natural according to the recommendations of the FSA.

In paragraph 51 of their document Criteria for the use of the Terms Fresh, Pure, Natural Etc in Food Labelling (Revised July 2008), they state:

“Natural” means essentially that the product is comprised of natural ingredients, e.g. ingredients produced by nature, not the work of man or interfered with by man. It is misleading to use the term to describe foods or ingredients that employ chemicals to change their composition or comprise the products of new technologies, including additives and flavourings that are the product of the chemical industry or extracted by chemical processes.

The full document can be found here: http://www.food.gov.uk/multimedia/pdfs/markcritguidance.pdf

Your 'With Blueberries, Pistachios and a Yogurt Coating' product contains both glucose syrup and sugar:


The processes by which sugar and glucose syrup are created means they do not qualify as 'natural' under the FSA's definition:

In the case of glucose syrup, this starts out life as a starchy food like corn - the process by which various forms of glucose are created from starch are described in the Production - Commercial section of the Wikipedia entry for glucose:

"Glucose is produced commercially via the enzymatic hydrolysis of starch.... This enzymatic process has several stages. In the gelatinization stage, a slurry of starch is heated to 105 °C, and the enzyme, α-amylase, is added. In the liquefaction stage, the mixture is held at 95 °C for 2 hours. In the last stage, known as "saccharification", the partially hydrolyzed starch is completely hydrolyzed to glucose using the glucoamylase enzyme from the fungus Aspergillus niger. Typical reaction conditions are pH 4.0–4.5, 60 °C, and a carbohydrate concentration of 30–35% by weight. Under these conditions, starch can be converted to glucose at 96–97% glucose, "glucose syrup" over 1–4 days."

As for sugar, the processes required to produce this from beet or cane contain a number of steps which are described on the Food Info web site. These include steps like:

"Carbonatation is achieved by adding milk of lime [calcium hydroxide, Ca(OH)2] to the liquor and bubbling carbon dioxide through the mixture. The gas reacts with the lime to form fine crystalline particles of calcium carbonate which occlude the solids"

"Phosphatation is a slightly more complex process that is achieved by adding phosphoric acid to the liquor after it has been limed..."

These descriptions clearly indicate that sugar and glucose do not fall under the FSA's definition of natural. Here is their description again with the key parts highlighted:

“Natural” means essentially that the product is comprised of natural ingredients, e.g. ingredients produced by nature, not the work of man or interfered with by man. It is misleading to use the term to describe foods or ingredients that employ chemicals to change their composition or comprise the products of new technologies, including additives and flavourings that are the product of the chemical industry or extracted by chemical processes.

Please explain how you can justify implying this product is natural when clearly according the FSA's guidelines not all the ingredients are natural.

Yours sincerely,
Methuselah

P.s. in case you were planning to point out that it is your company, not the product itself that is described using the term 'natural' (and that the guidelines therefore do not apply), I should warn you that readers of this blog tend not to have the wool pulled over their eyes quite that easily. Clearly you seek to imply that your products have natural ingredients by the way you market them and to suggest otherwise would not look good.

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See Also:
The Worst Sugar Pushers of all: Health Food Stores
Why is there Sugar in my Chicken?