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Formulating a Clean Label

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Photo: Kerry Americas

On the surface, the term “clean label” doesn’t seem complicated. It might be natural, possibly organic and perhaps free from synthetic chemicals.

While that is true, a simple definition doesn’t apply to all foods. The acceptance of certain ingredients varies among retailers, consumers and food developers. Different natural food stores have varying standards for allowable ingredients. Even the USDA and FDA sometimes differ in use of the term “natural” when it comes to flavors.

Yet certain trends hold true. Labels are more critical to retail products than foodservice. Even though consumers are becoming more aware and will study a retail ingredient statement, they are less likely to ask for this information in a fast food outlet or restaurant environment.

According to Mark Bento, technical director, Savory Flavors, Mastertaste, Teterboro, NJ, perceived freshness and wholesomeness of ingredients is gaining importance. “The key is minimally processed,” he says. In flavor development, “you can only use methods the consumer would probably do in their kitchen.” This would include using natural ingredients and heating or fermenting. Consumers are looking for ingredients they might find in their own cabinets, such as brown sugar or corn starch.

While the number of ingredients in the average R&D lab might fill several kitchen pantries, it’s worth looking at a few broad categories for a clean label.

Flavor first

Harshad Patel, Ph.D., technical director, savory flavor creation & analytical, Mastertaste, says: “Natural flavors such as citrus or mint are easy to create, partly because the raw materials which are used in making them, such as citrus oils, come from the name sources, such as orange peel, lemon peel, lime peel and tangerine peel. Similarly, spices are easy.”

FDA considers flavors natural if they are a natural oil, oleoresin, essence or extractive. Also included are protein hydrolysates, distillates and products of roasting, heating or enzymolysis, which contains the flavoring constituents derived from spice, fruit, vegetable, plant material, meat, dairy or fermentation products whose significant function in food is flavoring rather than nutritional.

Sometimes, natural flavors are combined so that flavors naturally derived from additional sources go together to make a particular flavor. A natural strawberry flavor, for example, would have components of natural strawberries.

It might be labeled “natural flavor with other natural flavors” if it is combined with other flavors that simulate, resemble or reinforce the strawberry flavor.

Patel says nearly all flavors can be made natural, but some are more difficult than others: “Strawberries may contain 400, 500 or more flavoring ingredients. Even though it exists in the natural fruit, regulations do not permit us to use those same ingredients. We are using only those which have gone through toxicological evaluation and have been approved by the FDA. That limits you to the variation and the profile that you can create to match closest to nature. For a practical purpose, it would be very difficult to compose a formulation using 500 ingredients.”

Thus the flavor will not exactly mimic the original. “There tends to be an artificial nuance of flavor,” Patel continues. “In a food matrix, starches, sugars and acids compose the complete flavor. When you’re trying to add the same flavor to a candy, the matrix is very different and, therefore, no matter what, it will taste different.”


Definitions and guidelines for “natural ingredients” can vary by country, by regulatory agency, by market and even by individual retailer.

It’s also a challenge when converting a consumer-accepted, artificially flavored product to a clean label. “We can create something very close, but it may not be identical,” says Patel. “From a consumer point of view, the difference may be marginal. But if other customers say it has to be identical, then it is a big challenge. Many of these materials, which are artificial, are not always available as natural today. A lot of snack products contain jalapeño flavor, which is artificial. There’s not a way to create that flavor in the strength, the price and the profile from a natural source.” He names one specific characteristic compound in jalapeño, 2-isobutyl-3- methoxypyrazine, which is not available as natural.

Candy flavor, such as cherry, is an accepted profile. “This is very high in benzaldehyde, which almost tastes artificial,” Bento says.

Natural flavors are often derived from more-expensive, and sometimes less-available, raw materials and can involve complicated processing. “For enzymolysis, the yield is in 2% or less vs. in chemical processing, where you can have yields up to 50%, 80% or to 100%,” Bento says. “That has an effect on the cost of the raw materials and the flavor. Every manufacturing step adds cost to the process, as well as the final product.” A natural flavor may have a multi step process that, for certain types of flavor, doesn’t drive the cost as high as one would think.

The cost can be even higher because of variations in the term natural. Some natural-food stores, such as Wild Oats Markets, Inc., Boulder, CO, subscribe to different criteria than the FDA definition. “A spice extract is normally made by solvent extraction and considered natural,” Bento says. To meet Wild Oats requirements, “you have to use a CO2- extracted material, which costs more due to processing.”

It’s critical to understand the customer’s definition of natural. Patel says it’s important to ask if the customer is seeking an FDA- or USDA-approved label. “We submit our formulation to USDA food review, and they say how it should be labeled. A consumer product is not always a USDA product. Many times it is just an FDA product.”

Generally, by the USDA definition, ingredients such as spices, spice extractives and essential oils can be labeled “natural flavors.” Ingredients that may have a purpose beyond flavor, such as flavor enhancers like dried chicken stock, autolyzed yeast and hydrolyzed proteins, must be listed by the common name.

Reaching a global marketplace is especially difficult. “Some countries work by a positive list, and some work with a negative list,” Patel says. “You are looking through pages and pages of paper to really understand what is acceptable in all these countries that you’re trying to produce the flavor for. When we work for global companies, they ask for an acceptable global label.”

Enhancement options

Use of monosodium glutamate (MSG) and ribotides (disodium inosinate and disodium guanylate) has been steadily falling out of favor due to negative consumer perception of glutamates and so-called “hidden glutamates.” Yet these compounds, which contain flavor-stimulating amino acids, add a unique quality to food.

Foods such as tomatoes and mushrooms naturally contain glutamates. At low levels, they can enhance flavors without contributing overpowering notes. Hydrolyzed vegetable protein (HVP) or autolyzed yeast extract (AYE) are accepted in some markets.

Chris Warsow, executive chef, Bell Flavors and Fragrances, Northbrook, IL, says his company offers a flavor enhancer that qualifies for “natural flavor” on the label. “It’s a reaction flavor that gives you a savory, umamitype of effect. It balances your flavors and heightens and boosts your top notes. I call it ‘the magic bullet,’ because it rounds out your flavors and bumps up your top notes without saying MSG on your labels.”

According to Patel, a lot of new knowledge about how we sense flavor is being developed. “We’re looking at flavor compounds that trigger umami receptor sites on the tongue,” he says. “There are gene proteins which have been identified as responsible for the perception of certain taste. T1r1 and T1r3 are responsible for umami taste perception. For bitter taste, T1r2s, there are almost 24 genes responsible. Understanding various natural materials that can trigger these genes allows you to actually modify the taste of the food to make it more salty, sweet or whatever you are looking to do.” T1r3 is a gene common to umami and sweetness taste perception.

This technology is used in salt modulation, an effect becoming increasing sought after in the food industry as companies look for sodium reduction. “In salt, nothing crosses the ion channel on the tongue other than sodium,” Bento says. “When you have no salt in there, your flavor profile totally collapses and all of your descriptors. What we try to do is look at umami receptors. That tells the brain, ‘I’m getting more flavor and just simulating getting more salt.’ All the flavor attributes increase.” These new technologies are also being used in replacing MSG and the ribotides.

Colorful quandaries

Contrary to popular belief, there is no such thing as “natural color” according to U.S. regulations. “Natural colorants are loosely defined by the industry as those colorants that are derived from agricultural, biological and mineral sources; are obtained with simple extraction processes; and have a long history of safe usage,” says Stephen Lauro, president, colorMaker, Inc., Anaheim, CA. “While industry operates with this working definition of natural colorants, FDA takes an entirely different approach. FDA does not recognize natural colorants. Rather, FDA regulates two distinct types of color additives: certified and exempt from certification. Color additives exempt from certification are commonly known as natural colors.” These exempt colors are listed in Title 21 Code of Federal Regulations Part 73.

Some exempt color additives can be synthetically prepared. “In this event, the synthetically prepared color additives are believed to be identical in chemistry to the molecules produced in nature,” Lauro continues. “Such color additives are known as nature-identical. The most-common form of a nature-identical color additive exempt from certification is beta carotene.”

Unlike artificial colors, most natural colors display sensitivities to light, pH, heat and other ingredients, like ascorbic acid or minerals. “These sensitivities compromise the shelf stability of natural colorants,” says Lauro. “Not all natural colorants display the same sensitivities. Turmeric is very sensitive to light, while caramel color is not. Red cabbage extract is sensitive to changes in pH, while lycopene is not. Beet juice is very sensitive to heat, while carmine is not.”

Carefully consider storage, packaging, processing and product parameters when selecting natural colorants. “Some natural colorants, particularly anthocyanins such as red radish extract and red cabbage extract, can add an off-odor and/or a vegetable-flavor note,” Lauro cautions. “While such flavor contributions are minor, they can be noticeable in lightly flavored beverages or in some ethnic cuisines, such as Oriental soups.”

For ice cream, Lauro recommends beet juice. Because it is sensitive to heat, it fares well in cold desserts.

Carmine is generally stable to light, pH and heat. At different concentrations it can produce a light-pink to a dark, wine-red hue. “Unfortunately, carmine is neither kosher nor vegan, because it is derived from an insect,” he says. “Further, beginning in Jan. of 2008, all products containing carmine must declare it as such on the ingredient list. The phrase ‘color added’ may not be used for carmine after Jan. 2008.”

Grape skin extract is permitted as a color additive exempt from certification in beverages, while grape juice is permitted as a color additive exempt from certification in non-beverage products. “While these regulations are clear, in practice grape skin extract and grape juice are often used interchangeably,” Lauro says. “Both are good choices in beverages where, at an acidic pH, they are red. However, both grape skin extract and grape juice are somewhat sensitive to heat and, therefore, should be thoroughly tested in food or beverage products subjected to heat processing. Finally, grape skin extract is typically not available kosher-certified, while grape juice is.”

Nothing colors salt as vibrantly as paprika oleoresin.

“Some paprika extracts also contribute flavor and heat (capsaicin), depending on how the extract has been processed,” Lauro warns. “Paprika oleoresin finds limited application in foods and beverages, primarily because it is truly oil-soluble. Most food and beverage products are aqueous systems.” Its color comes from its xanthophylls, capsanthin, capsorubin (red) and beta carotene (yellow), and it is somewhat light-sensitive.

Turmeric provides a bright-yellow color and comes in two forms. Turmeric oleoresin is oil-soluble or water dispersible, depending on how it is prepared. Curcumin powder is an insoluble, bright-yellow powder. “Both turmeric oleoresin and curcumin powder are sensitive to light,” Lauro says. “The most-common applications for turmeric are pickles, where it is used to pump up the green color of the cucumber, and mustard, where it is used as the primary color.”

Caramel color is produced by heating sugar and other carbohydrates, sometimes with acid, under strictly controlled conditions, for an array of brownish hues. A small amount of caramel color can standardize products where color variation occurs from other natural ingredients. Additionally, it can add color depth by subduing bright colors. Caramel color is unaffected by pH or heat processing. There are four classes of caramel color that are stable in different environments.

Bulking and thickening

Flour has long been the thickener of choice for chefs. But Joe Lombardi, business manager, wholesome ingredients, National Starch Food Innovation, Bridgewater, NJ, notes “when it comes to withstanding the rigorous processing conditions of large-scale production, traditional flours have limitations.” Typically, they deliver neither ease of use nor long-term stability processed foods require.

To meet this need, Lombardi’s company has developed a line of functional flours. “These products are designated simply as wheat flour on the label, yet they are different from traditional flours in that they offer manufacturers the ability to consistently create and market high-quality, convenient, processed foods,” he says. The flours are not bleached or chemically processed.

One functional flour is pre-gelatinized and easy to swell. For use in dry soups, gravies, sauces and microwaveable applications. “It is also useful for eliminating hot prep steps in manufacturing processes,” Lombardi suggests. It thickens quickly “when added to broths, milk, juices or vegetable extracts,” he says, recommending addition at a rate of 7% to 12% on a dry-solids basis. “In moderate- to high-solid systems, 3% to 6% may be added on a dry-solids basis.”

Another functional flour retains the positive attributes of flour—opacity, texture and flavor balance—while offering processing tolerance, resistance to breakdown, viscosity and textural variation in retorted or kettle-cooked soups, sauces and gravies. “This offering contributes a short, heavy-bodied texture to neutral and acidic food systems processed under high-temperature and high-shear conditions,” Lombardi says. “It also appears to be more consistent on steam tables. Food product makers may add 4% to 6% on a dry-solids basis.”

Lombardi describes the third functional flour as a breakthrough product, because it is a highly freeze/thaw-stable wheat flour. “This functional flour may be included in frozen and refrigerated soups, sauces, and RTE meals,” he says. “It can also offer foodservice operators flexibility in preparation and storage.” Suggested use is 2% to 4% on a dry-solids basis.

Yet most food developers reach for starches. “Native starches, with their simple label designation, are the best options for natural, organic, clean-labeled food products,” Lombardi suggests. These include corn, tapioca, potato and rice. Unmodified starches, however, “lack tolerance to heat, pH and mechanical shear, and lead to over-processed starch and loss of water-binding capability and viscosifying properties,” he says.

National Starch Food Innovation has created a line of process-tolerant native starches. These are “physically processed, offering the processing performance of traditional modified food starches, yet retain their native starch designation,” says Lombardi.

Among these starches are cold-water swelling (CWS) functional starches. “Dispersions of this offering provide exceptional clarity, sheen and smoothness when compared to dispersions of established CWS thickeners,” Lombardi says. “Its functional properties are similar to modified starches, yet meet the labeling criteria of native starch.

All or nothing

To reposition a food product as natural or organic, one must clean the entire label declaration. “Accordingly, food formulators need to find alternatives to a number of functional, yet unacceptable, ingredients,” Lombardi says. This not only includes the ingredients discussed, but may encompass things like preservatives and emulsifiers.

“The key is to truly understand the customer’s expectation,” says Cynthia Sasaki, senior R&D manager, Kerry Savory, Kent, WA. Clean to one customer could mean nothing artificial, but another customer may want nothing artificial, including no MSG, HVP or modified food starch. “The developer needs to select raw materials that fit the customer’s requirement,” she continues. “Doing your due diligence with your vendors up front will save time later in your development. You will find out quickly which vendors understand their raw materials and which vendors truly understand the meaning of clean.”

Cindy Hazen, a 20-year veteran of the food industry, is a freelance writer based in Memphis, TN. She can be reached at cindyhazen@cs.com.

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