"Natural" Foods Are Distinct From Organic Foods:
Comments of the Organic Trade Association on
Docket Number FSIS 2006-0040
January 11, 2007
Submitted by Tom Hutcheson, Regulatory and Policy Manager
Product Labeling: Definition of the Term "Natural"
OTA wishes to comment on the definition of "natural" foods, and wishes to emphasize the distinction between products identified as "natural" and those that qualify for the "organic" label.
Historically, both "natural" and "organic" product claims originated from consumer interest in more healthful, nutritious products that are unadulterated by potentially harmful additives, and whose nutrient content has not been degraded by the processing used in modern industrial food production.
However, the "organic" claim has diverged from "natural" in several important ways.
First, the term "organic" refers to a system of agricultural practices and certification to production and handling standards. "Natural" refers to the end product, that is, one that is minimally processed. Specific definitions and descriptions of "organic" were originally developed by the farming community, and were later refined to better reflect consumer concerns. Processing requirements for organic products focus on maintaining the integrity of the raw agricultural ingredients by protecting them from commingling with nonorganic products or contamination by prohibited substances at every step.
Further, the value of the "organic" label has evolved through a self-regulated system of third party verification that provides credibility and consumer confidence in organically labeled products. Organic product claims are backed by a system of independent verification and consistent national and international standards that are enforced by USDA. This includes requirements for annual monitoring of all certified entities, and audit trails that are adequate to identify the source and quantity of all ingredients used in processed products. National Organic Program standards cover every aspect of production and handling, from soil management through packaging, for every type of agricultural product.
OTA's main concern is that any regulations governing the "natural" label make clear that a product that qualifies for this label cannot be presumed to be equivalent to an organic product. The "natural" label does not provide any information about how an animal was raised or how the product was produced.
For example, organic products may not include genetically modified organisms (GMOs) in any aspect of production or handling, including as livestock feed. Livestock must be fed only organically produced feeds, ruminants must have access to pasture, poultry must have outdoor access, and feeding of slaughter by-products is prohibited. All antibiotics and hormones, as well as most parasiticides, are prohibited in organic livestock management. "Natural" livestock and poultry products, on the other hand, may come from livestock that were kept in cages without access to the outdoors, administered a full range of approved veterinary drugs for the treatment of disease, fed genetically modified corn and soybeans.
While an organic product may also be considered natural, this is not necessarily the case. Some confusion may arise from the requirement that, to the extent possible, only natural or "non-synthetic" substances can be used to produce an organic product. Exceptions to this requirement are strictly limited to synthetic substances that appear on the National List, following extensive review and public comment. Organic products may or may not be "minimally processed," and may include additives such as antioxidants, nutrient fortification, emulsifiers, thickeners, and flavoring, so long as any such additives or processing aids that are not organically produced are included on the National List and comply with other National Organic Program requirements (i.e., they were produced without GMOs, irradiation or sewage sludge, and were not extracted with volatile synthetic solvents).
OTA Responses to Questions Posed by FSIS:
1. Considering the types of food processing methods that are commonplace today, as opposed to 24 years ago when the policy on "natural" claims was established, is it reasonable to include as part of the definition of "natural" a stipulation that products, to be eligible to bear the claim, can be no more than minimally processed? Are there any accommodations necessary to allow for certain operations because food processing and packaging techniques for enhancing safety may disqualify a product as "natural?"
No comment on this question.
2. What are the implications and conflicts that exist with regard to using current and new food processing methods, e.g., chlorine in poultry chillers; steam pasteurization of carcasses; high pressure processing; and modified atmosphere packaging and uses of certain classes of ingredients, e.g., antimicrobial agents, and the meaning of the claim "natural" on the labels of meat and poultry products?
OTA wishes to point out that use of antimicrobial food contact substances is permitted in organic processing, as are high pressure processing, controlled atmosphere packaging and steam pasteurization.
3. Are there available data, in addition to the data provided in the petition, from consumer studies on views, perceptions, and beliefs about what the claim "natural" means on the labels of food products, including meat and poultry products? What do consumers think that the terms "minimal processing," "artificial and synthetic," and "preservatives" mean?
The definition of "synthetic" provided by the Organic Foods Production Act (OFPA) and the National Organic Program is: A substance that is formulated or manufactured by a chemical process or by a process that chemically changes a substance extracted from naturally occurring plant, animal, or mineral sources, except that such term shall not apply to substances created by naturally occurring biological processes. Because this definition is of such significance for interpreting the regulations, the National Organic Standards Board is currently considering a recommendation to clarify it. For example, the chemical changes resulting from cooking or baking would appear to render the product synthetic under this definition, but nobody has argued that organic products should not be cooked or baked. We suggest that, should "natural" be defined as containing no synthetic ingredients, FSIS consider the dilemma posed by the inclusion of many common household ingredients, such as baking powder and pectin (low-methoxy), in the synthetic category.
4. Do food safety and consumer protection benefits of using what historically may have been considered more than minimal processing techniques and antimicrobial agents outweigh conflicts with the meaning of "natural?"
In considering this question, OTA does not know of any statistically valid study that shows any adverse differential incidence of food safety problems or consumer protection for natural or organic production as contrasted to conventional or maximally processed meat or poultry products.
OTA appreciates the opportunity to comment on this important subject, and we look forward to ongoing communication regarding the regulation of products claiming to be "natural."