When a characterizing flavor is included in the product name or implied through a graphic, there are specifics that must accompany the flavor name in all locations on the package. It also must be presented in at least half the type size of the characterizing flavor name.
First, let’s look at the term “natural flavors”.
There are 3 main sub-categories for natural flavors.
- FTNF (from the named fruit): All flavoring materials come from the characteristic flavor at hand i.e., an orange Flavor FTNF only has extracts and chemical isolates from orange. The biggest concern with many “FTNF” flavors, is they are often linear and lacking depth that could be delivered better with flavoring materials outside the “orange” world.
- WONF (with other natural flavors): Flavoring materials come from the characteristic flavor at hand, in addition to other flavor materials that come from a natural source, that help enhance, balance, and add complexity – resulting in a more realistic, authentic flavor. Flavorings are comprised of sometimes hundreds of chemical compounds, so WONF flavors allow the flavorists to provide a very realistic profile for manufacturers.
- Natural “TYPE” flavors: “types” are made from natural flavoring raw materials, but none of the materials come from the flavor at hand. Often flavor “types” are created because:
- An agricultural source does not exist, e.g., Natural Hot Chocolate Type Flavor, hot chocolate is a man-made, so a flavor chemist cannot use a direct extract as a building block to create the flavor.
- If an allergen-free “allergen flavor” is needed, e.g., an allergen-free Natural Peanut Butter Type Flavor cannot use components from real peanut, therefore it would be considered a “type”
- This type of flavoring has a special caveat based on the characterizing flavor trying to achieve. If the product created is only being provided its flavor via the “type” flavoring and does not have inherently any other ingredient developing independently the characterizing flavor, then that product is actually deemed “artificially flavored” due to the chemical characteristics of a natural “type” flavor and would need to disclose that anywhere the characterizing flavor was listed.
Next, briefly let’s examine when artificial flavors come into play.
Artificial flavors: They are added to simulate or reinforce the characterizing flavor and they rely on flavor ingredients other than natural sources. Throughout the years artificial flavors have taken the backseat in many consumers minds with preference for naturally sourced flavors, but it is important to note that compositionally there is no difference between the two, the starting material may be different but the chemical compounds in the end product are very similar.
Natural and Artificial Flavors: Flavor ingredients are from named natural sources and other substances, including non-natural. There is no specific regulatory declaration which speaks to the two in combination, however it is industry standard that when both are used together that both are listed accompanying the flavor characterized on the package.
Lastly, let us touch on when the use of the term “flavored” is required to be placed on packaging following the characterizing flavor.
The easiest way to create distinction is by determining if the characterizing ingredient provides enough of the flavor independent of the added flavoring. If it does, then the term “flavored” is not required on the PDP etc. following the characterizing name.
- Ex. Blueberry Pie- which contains enough blueberries to create a recognizable flavor separate from the natural flavoring added.
If; however, the product does not have an ingredient which provides the profile, then it is required to list the term “flavored” on packaging.
- Ex. Blueberry Protein Bar- which contains minimal to no blueberry powder (only for color) or even uses some other source to color and a natural flavor. In this example you would be required to list that product as Blueberry Flavored Protein Bar.
Flavor Qualifiers for Labeling
|Type of Flavoring||Description||Label Claim (PDP*)- *Required anywhere characterizing flavor is stated||Label Claim- ingredient statement|
|Natural (FTNF)||All flavor ingredients directly from the characterizing flavor||Naturally Flavored||Natural Flavors|
|Natural with other natural flavors (WONF)||Contains flavor ingredients from the actual characterizing flavor and pulls flavor notes from other natural sources.||Naturally Flavored with Other Natural Flavors||Natural Flavors|
|Natural Type||Contains flavor ingredients from natural sources to create a profile that delivers the characterizing flavor.||If the type flavoring is making up the characterizing flavor, then the product is… Artificially Flavored||Natural Flavors|
|Natural and Artificial||Flavor ingredients are from named natural sources. and other substances, including non-natural.||Naturally and Artificially Flavored||Natural and Artificial Flavors|
|Artificial||Delivers the characterizing flavor taste but relies on flavor ingredients other than natural sources.||Artificially Flavored||Artificial Flavors|