In recent years, consumers have driven the trend toward clean label products and increased brand transparency. However, the shift brought its share of growing pains.

Jennifer Stephens, vice president of marketing at Fiberstar Inc., explained: “Since ‘natural’ or ‘clean label’ is not regulated and is open for interpretation, it gives some manufacturers some wiggle room when formulating products.” She noted a company’s consumer preference tests will dictate which ingredients are considered acceptable in the food products it sells, but “ironically, some of these ingredients that are deemed OK are processed with chemicals and/or solvents, which is not natural. However, they are accepted by the consumer” because of a product’s clean ingredient declaration.

Jennifer Tracy, senior marketing manager, Global Wholesome Springboard, at Ingredion Inc., also acknowledged the powerful role of the consumer. “Choosing a clean label ingredient supplier really has to start with the consumer. The consumer's perception of clean label influences the ingredients you use and claims you include on your label. Ingredients have to be recognized, accepted and expected in the packaged food or beverage, and these preferences vary by region,” she stated, pointing to Ingredion’s proprietary research. For example, Tracy said consumers in South America favor corn starch in a dressing, whereas consumers in North America and Asia Pacific prefer a rice flour.

Nesha Zalesny, technical sales manager at Fiberstar Inc., suggested, “Something as innocuous as a chocolate chip cookie is a great example of how difficult clean label formulating can be. Flour in the United States is fortified with vitamins with chemical-sounding names like niacinamide. This ingredient is an important form of nutrition, but because it sounds ‘chemical,’ it may be viewed as suspicious. Sodium bicarbonate (baking soda) also sounds like it is not a clean ingredient. Delve a little further, and one can see the palm oil, butter and/or margarine (partially hydrogenated vegetable oil) that is used to keep the baked good tasting fresh have their own challenges.”

She continued, “Sugar can also face sustainability and sourcing questions. This is a simple home-baked type of cookie. Products with longer shelf life will have even more issues, especially in packaging and ingredients.”

As brands try to discern and align with the ever-changing preferences of consumers, a variety of missteps can result. One of the most egregious offenders is deliberate misrepresentation. “Adulteration of foods for economic reasons remains an issue in the global food and beverage industry,” noted Steve Taormina, business unit manager for NSF International’s Consumer Values Verified program. “Pure, real honey, for example, can be mixed with invert sugars to ‘stretch’ its value, but a finished-product label might only state ‘honey’ on the ingredient panel. This, to me, is greenwashing the product for consumers.”

These unscrupulous practices have escalated consumer skepticism of green product integrity. Steve French, managing partner at Natural Marketing Institute (NMI), shared data from the firm’s annual consumer insights & trends report, “2018 State of Sustainability in America.” It revealed more than 60 percent of consumers ages 18 and above agreed with the statement, “I feel many companies label products as ‘green’ just so that I will buy them.” Millennials were the most skeptical, weighing in at 68 percent agreement. NMI noted brands should be specific in communicating their green efforts, which can help regain consumer trust.

Founded in 1988, the billion-dollar “always organic” brand Organic Valley was clean label before clean label was a thing. Tripp Hughes, senior director of consumer strategy, said “watching ‘clean label’ get abused is a bummer. It confuses consumers and erodes trust on a market scale. That erosion requires the brands and products with integrity to pivot further and make sure their communications are clear and cut through the clutter.”

When it comes to those companies intentionally practicing deception, Hughes cautioned, “Consumers really care about authenticity, transparency and integrity. So trying to fool them into buying products that look ‘green’ but aren’t really ‘green’ is a big gamble,” particularly in an age where “consumers are voting with their dollars.”

The NMI report concurred, indicating approximately 40 percent of consumers in the lifestyles of health and sustainability (LOHAS) group stopped buying a product after learning a company didn’t practice social or environmental responsibility.

The data also showed three-fourths of the general population agreed with the statement that almost all companies are saying they’re environmentally friendly, so it’s hard to know who’s telling the truth. Although Matures were the most mistrustful (84 percent), the younger generations were more likely to seek out proof of a company’s altruism. Approximately half of Millennials and Gen Xers reported they look for proof when a company makes a claim about being socially or environmentally responsible, and in general, nearly one-third of both demographics research a company’s accountability stance prior to purchasing its products.

Organic Valley has been at the forefront of truth in advertising for a quarter century. “When we started out telling our authentic and transparent, farm-to-table, organic story over 25 years ago, using images of our farmer as heroes, we didn’t really expect the day big ag and big food would so closely mimic our communications,” Hughes shared. “When we have massive, well-funded brands crowding the marketplace with their food/farm stories, there is no doubt consumers are going to get confused. Some consumers will take it at face value, but others will be more skeptical and want to know more.”

Challenges Abound

Even the most well-meaning companies can find themselves on the wrong side of clean label—which often circles back to a catch-22 in consumer perception. Tracy offered the example of organic maltodextrin. “Consumers see the organic claim and associate it with clean label because of its clear and regulated labeling guidelines. They can trust that the product is going to meet the standard it promises. Yet, the base material, maltodextrin, is not perceived as clean label. In fact, only 9 percent of consumers globally find this ingredient acceptable according to our proprietary consumer study. This conflicting messaging creates a disjointed value proposition and diminishes the credibility of the product to the consumer. Ensuring a connection between labeling and consumer perception will only become more important as manufacturers adapt to support the growing demand for transparency.”

Kantha Shelke, Ph.D., principal at Corvus Blue LLC, indicated many factors can complicate clean label. For instance, “Flavor ingredients commonly incorporate propylene glycol as a solvent and emulsifier for flavor mixtures. Science shows the ingredient to be safe in the amounts used in foods. Because propylene glycol is derived from petroleum—which, by the way, occurs in nature—it is not considered a clean label ingredient and scares some food manufacturers from including it or declaring in on their labels.”

Shelke clarified that when used a processing aid in accordance with food laws, propylene glycol can be used in clean label products—just not declared openly, “because it is a part of the benign catch-all term ‘natural flavor.’”

As a certified food scientist, Shelke is particularly concerned when consumers lacking a thorough understanding of nutrition force the hand of manufacturers. She identified a “prevailing misconception that honey or agave is somehow safer and better than common sucrose (table sugar) or high fructose corn syrup. Science-based evidence shows it is the amount of added mono- and di-saccharides in a product that separates the nutritious from the harmful.”

She added, “Refined starches used in clean label gluten-free versions of consumer favorites—when consumed by those who are not clinically tested for gluten allergy—have a high risk of unhealthy blood sugar and triglyceride levels. What’s clean for ignorant activists lacking a science and nutrition education is far from clean, and downright harmful for food scientists with a solid understand of nutrition and physiology.”

Shelke said another ingredient drawing consumer scrutiny is carrageenan, “a seaweed-derived emulsifier misconceived as being harmful to the gut.” She noted its functionality often delivers the right emulsification and therefore, the expected appearance and texture in nondairy beverages that require stabilization for even suspension without separation during storage and handling. Alternatives have not proven as effective in many beverage formulations, so Shelke recommended using carrageenan in formulations, but partnering it with education detailing how the ingredient works, that it has been used safely for millennia, why the amounts used are safe, and what carrageenan offers in the beverage.

Claims and Certifications

One route brands can go to set themselves apart is through claims and certifications—but again, consumers are increasingly savvy and searching for authentication.

According to Tracy, “Understanding consumer attitudes and beliefs enables manufacturers to include claims and ingredients that are of interest, believable and consistent with their expectations for a given product. Claims are designed to capture the attention of the consumer, but there's a risk to using claims that are not consistent with the ingredients and the expectations that the consumer has for the product. Consumers need clear and consistent messaging that enables them to make informed decisions, which in turn will foster credibility and trust in the brand. This is especially important as consumers—and more recently, brands—take aim at specific ingredients that are perceived as undesirable.”

Taormina offered non-genetically modified organisms (GMOs) as an example. “‘Non-GMO’ certification is difficult to achieve,” he suggested. “There are requirements to demonstrate if the ‘high risk’ corn- and soy-based ingredients, for example, came from GM or non-GM varieties. If a brand or manufacturer cannot provide supply chain transparency and traceability to farm-level origin, then it could lead that brand to making ‘non-GMO’ claims, when in fact, some of the original crops were GM.”

Kristin Wheeler, communications manager at the Non-GMO Project, concurred. “We recognize the risk of greenwashing, especially when it comes to consumer choice. GMO labeling that is not clear, inclusive or meaningful will not provide consumers the GMO transparency that they have been demanding for decades,” she said.

“At the time the Non-GMO Project was founded, unsubstantiated GMO-free and non-GMO claims were rampant,” Wheeler continued. “The retailers and industry leaders that started the organization realized that to counter greenwashing and to provide GMO transparency to shoppers, there needed to be a standardized definition for non-GMO products in the North American food industry. This led to the development of North America’s only third-party verification program completely dedicated to GMO avoidance.”

Zalesny echoed the importance of choosing “reliable and recognizable third-party certifications that are meaningful to your product and to your consumers. There are a lot of third-party certifiers out there; it seems like every year there are more and more specialized certifications. So many manufacturers and consumers feel like these are a simple money grab. It is so important that manufacturers do a gut check and do market research to determine which certifications resonate and engage with their consumers. The audit process itself should feel like work. How meaningful is the audit exercise if a manager is simply signing a document and then a check?” she asked.

Taormina agreed with Zalesny’s sentiment that a quality third-party certification can help a brand demonstrate to retailers and consumers that it is taking extra measures to ensure its label claims are truthful. In addition to non-GMO, his examples included gluten-free, raised without antibiotics, and True Source Honey.

Organic is perhaps one of the strongest certifications, thanks in part to the efforts of the Organic Trade Association (OTA). Laura Batcha, the organization’s CEO and executive director, explained, “Organic is the only eco-label that is a federally regulated and enforced term and with third-party certification. There are stiff penalties for fraudulent organic labeling, and the Secretary of Agriculture and USDA's National Organic Program (NOP) are currently prioritizing efforts to further strengthen oversight and enforcement.”

Batcha said the third-party certification entails an inspection of every certified organic farm and business at least annually, unannounced and compliance inspections, collection of samples to analyze for pesticides and other prohibited substances, and suspension or revocation of organic certification if organic businesses fail to comply with the rules.

Tips for Brands

With so many angles to consider, brands looking to support clean labels and transparent products can start with a few basics. “First, manufacturers need to understand what their target market perceives to be clean label versus not,” Stephens stated. “Each consumer market has different expectations for each one of their brands. For instance, some consumers may view a food product containing no allergens as clean label. In this case, manufacturers need to vet out ingredient suppliers with robust allergen-free programs who have a track record of keeping their ingredients free from contamination. Understanding the supplier’s supply chain and processes from origin to final product is key in defining a reputable ingredient supplier.”

Patrick Hart, specialty grain merchant at Ardent Mills, echoed the importance of supply chain accountability. “From grower to miller, supplier, transporter, baker and end user, it’s important to create partners throughout the supply chain to assure that organic/clean label products are handled and delivered properly every step of the way.”

Zalesny suggested, “A second step would be for product managers to analyze the product’s entire life cycle. This should start with ingredients but also include packaging. Where the ingredient or packaging comes from, how it is produced, and where the packaging goes once it’s used are important factors to understand. It is not enough to have green on the label and have consumers believe it is a clean label product. Any claims should be verifiable with data that is easy to access for consumers. At the very least, supporting data should be easy to find on the companies’ web pages. Labeling should use simple, transparent language that is easy to understand.”

Tracy concurred the importance of on-pack messaging should not be underestimated, as it plays a significant role in shaping consumer perspective about the quality and believability of a product. “The type of ingredients and claims must be in-sync with the product and with each other,” she affirmed. “Consumers expect to see certain ingredients in a given product, and they associate specific claims with the inclusion (or exclusion) of ingredients. Disconnects between the messaging signal to the consumer that the product may not be as advertised.”

Perhaps the most important component of advancing clean label and transparency is educating consumers. Celeste Daughenbaugh, Corbion’s global market manager, savory, said, “With ingredient innovation happening so fast, consumers must be consistently educated to help them recognize and understand what’s in the foods and drinks they buy. Our industry has a responsibility to address knowledge gaps, fears and misunderstandings by providing sound and simple explanations.”

She pointed to vitamins and minerals as examples of healthy ingredients with common source names which may not be perceived as clean label. “It can be very difficult to source alternative ingredients that deliver the same nutrient potency and stability,” she shared. “This creates a very complex sourcing, formulation and costing challenge.”

Daughenbaugh said these issues must be tackled by the entire food sector and across entire organizations. “At Corbion, responsible, transparent ingredient labeling is not only the job of our regulatory team. We come together across many functions to ensure we are educated and able to support responsible labeling from concept to commercialization.”

Taormina also supported the industry-wide philosophy. “Distributors and retailers are an extra line of defense when it comes to protecting consumers from greenwashing. Business buyers and sellers should feel empowered to ask smart, detailed questions of the brands that are making label claims that are not third-party verified.”

One highlight of the clean label movement has been the willingness of business competitors to work together to advance the common good. “As humans, we are collectively rooting for a sustainable and plentiful future—we just may have different views on how best to get there,” Hughes commented. He said Organic Valley made a hard stance long ago in committing to produce food without the use of substances such as antibiotics, synthetic pesticides, GMOs and synthetic growth hormones. “While it creates more competition for us, we openly cheer as the industry tips in our direction and more companies embrace sustainable practices.”

Organic Valley also supports industry camaraderie. “When we learned that there was significant confusion about whether or not organic foods were produced without GMOs, we created a communication tool—a bug that can be used on packaging—that tells consumers ‘Organic is Always Non-GMO.’” Hughes said. The company offers it to other organic food producers to use at no cost.

Clean label is a complex arena—one that many industry organizations are making great strides in advancing. Zalesny maintained, “Most consumers are looking for recognizable ingredients. For some, it means easy-to-pronounce ingredients; to others, it may mean a short ingredient deck. Organic ingredients may be important to other consumers. ‘Clean label’ can be a rather amorphous target to try and hit.”

Due diligence is key, particularly when it comes to communication. Daughenbaugh recommended, “Being extremely transparent and very clear about what the ingredient is and what regulations guided its declaration is the only way to avoid misunderstandings or wrongdoings.”