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October 1, 2018
Consumer interest in where food comes from and how it is made is growing like wildfire. The impact of consumers’ desire to know more about their food can be seen on almost every label in grocery aisles and is resetting dinner tables across America.
To understand where this all began, there is probably no better place to visit than the Smithsonian’s American Museum of National History. There, while enjoying a faithful recreation of Julia Child’s delightfully cluttered television kitchen, visitors can also read up on how a rekindled interest in food in the last half of the 20th century gave rise to a movement that transformed American cuisine and changed how families shop and eat:
“Inspired by regional traditions of France and Italy, cooks, farmers, storekeepers and adventurous eaters led the charge to revitalize and reinvent an artisanal world of food largely abandoned in America. They turned to the fresh, local, and regional in the United States, and developed a new American cuisine. Within the context of mass-produced, mass-marketed, “fast,” and convenience food, the “good food” movement opened a national conversation about what and how Americans eat.” (“The Good Food Movement: Transforming the American Table, 1950 to 2000”)
Today, this kind of engagement with food has evolved to where it has become known, simply enough, as “The Food Movement.” In a nutshell, this movement encompasses the many people across America who have become passionately engaged with how their food is made and where it comes from. For food manufacturers, this means consumers are expecting—even demanding—to know how their food supply chain works and how their food gets from farm to table. The U.S. Farmers and Ranchers Alliance recently reported, 70 percent of consumers said their purchase choices were affected by how food was grown and raised, and three-quarters said they think about these issues while shopping.
The rise of the ‘process label’
Dramatic advances in food production, coupled with consumer concerns about the impact of modern farming on health and the environment have created demand for a new type of food label. Experts at the Council on Agricultural Science and Technology, who have studied this phenomenon, argued in an October 2015 report, “Process Labeling of Food: Consumer Behavior, the Agricultural Sector, and Policy Recommendations,” that “process labeling,” i.e., a label that focuses on how a food is made rather than what it provides in the way of nutrition or taste, can create consumer value by satisfying demand for stringent quality control (QC) and bridge the information gap between producers and consumers.
For the average consumer, interest begins with food’s ingredients, and consumers are increasingly looking for foods with clean labels. Unfortunately, the terms “good food” and “clean label” have no regulatory definitions, but the demand for this kind of labeling reflects consumer interest in production methods that yield ingredients that are simple and easy to understand. As an expert panel recently observed, such label communications are often about what was not added to a food:
“The ‘clean label’ trend has driven the food industry to communicate whether a certain ingredient or additive is not present, or if the food has been produced using a more ‘natural’ production method (e.g., organic agriculture). However, there is no common and objective definition of ‘clean label’.” (Food Research International. 2017;99:58-71)
The authors called on regulatory agencies to develop a common definition based on factors that drive consumers toward clean food choices, especially how a claim for a clean label might also convey a food is “natural,” “organic” or “healthy.”
Until regulators and policy makers can draw some boundaries, it must be remembered “clean label” is a subjective term influenced by individual consumer perspectives and preferences. It is possible to claim a product has a clean label—and nothing more—if it is made entirely of simple, easy-to-understand ingredients. The idea is consumers should not need a food ingredient dictionary or obtain a degree in food science to understand what is in food.
However, the desire for foods made from ingredients with familiar, easy-to-understand names could also include a desire for foods made without artificial ingredients, preservatives, added colors or bioengineering. All these messages can be easily understood by a food claiming to present a clean label.
‘We didn’t mean that’
It is especially important for food producers to remember they are responsible for ensuring every message a consumer reasonably takes away from a food label has to be truthful, non-misleading and adequately substantiated, per FDA and FTC regulations. Unintended messages can arise from a careless arrangement of claims and labeling elements, and an unintended message can make a label deceptive.
A clean label may be attractive, but is it necessarily healthy? That term is subject to an FDA definition and must be independently verified. Is a clean label necessarily organic? Again, a product cannot be described that way unless experts have independently certified the product meets certain standards for organic farming.
At the same time, the food producer must navigate certain FDA and USDA regulatory requirements, such as food standards of identity, that require the use of specified names for certain foods or food ingredients. These requirements may demand the use of a technical name, e.g., ascorbic acid, or a general description, such as “natural flavor,” either of which may put off a consumer in search of a clean label.
For meat or poultry products, the producer must focus on the predominant ingredient and ensure the name and labeling are USDA-compliant. Again, the challenges of unintended messages and inferences must be considered. Does a claim for “farm-raised chicken” mean the animal was kept in a “cage free” environment or “humanely raised?” As with organic, these terms have specific meanings that often require USDA’s inspection and verification.
Make the ingredients the main story
To address these issues, it is best a food producer selects ingredients and arranges label elements so the ingredients themselves become the main story. Several manufacturers, for example, invite consumers to look at their labels for “ingredients you can see and pronounce,” or promise “ingredients you know and love.” Consider, for example, the elements of labeling for KIND granola bars, including the invitation to consumers to examine the ingredient statement, and additional information is provided in a glossary on the website. Additionally, Campbell’s Well Yes! line of soups promises, “ingredients you know and love,” and reinforces that message on its website
At the same time, such labelers independently verify other claims, such as “healthy” or “gluten free,” and leverage the internet to help tell their ingredient story.
Claims about simple, less-processed ingredients can help food companies connect with certain consumers, but they can also present substantiation challenges, especially for companies with complex supply chains. Visibility across a complicated network of suppliers can be challenging when a company is marketing different products to satisfy consumers who want a clean label, on the one hand, and, on the other, consumers who want primarily good taste, value and/or nutrition.
The clean label product will require an independent, well-defined processing and sourcing network designed to support the use of ingredients and reasonable inferences that can be drawn from the labeling. Supply chains must be managed under strict control, with visibility to the point of origin, validation, inspection and continuous monitoring to avoid inadvertent crossover of ingredients. Reliable documentation and recordkeeping are essential.
Clean labeling can certainly help inform consumers about how a food is made and promote a feeling of interconnectedness between consumers and their food. Indeed, consumers feel it is their right to know what is in their food and how it is made. These realities require food producers be diligent in sourcing and careful in labeling. Remember, a clean label or process by itself doesn’t necessarily promote consumer wellbeing, and an ingredient doesn’t necessarily deliver a benefit simply by being present. For the food manufacturer, it is critical to navigate these matters when labeling and take control of all messages, both expressed and implied. This approach represents the best way for a food producer to “come clean” in labeling.
EAS Consulting Group’s independent advisor for food law and regulation, Steve Armstrong, has had more than 20 years of experience advising leading consumer products companies on marketing and regulatory matters. Prior to EAS, Armstrong served as the chief food law counsel at Campbell Soup Co., where he counseled Campbell businesses on food safety, food policy, labeling and regulatory compliance, including matters involving FDA, USDA and food agencies around the world. Armstrong is on the board of directors of the Food and Drug Law Institute in Washington and is a frequent speaker on food law issues.
Want to know more about why Regeneration and Biotechnology both matter in the future of food? Join us for the "Feeding the Good Food Future" workshop on Thursday, Nov. 8, at SupplySide West 2018. This workshop is underwritten by Orgenetics and Stratum Nutrition.
EAS Consulting Group’s (easconsultinggroup.com) independent advisor for food law and regulation, Steve Armstrong has more than 20 years of experience advising leading consumer products companies on marketing and regulatory matters. Prior to EAS, Armstrong served as chief food law counsel at Campbell Soup Co., senior marketing counsel at Energizer’s Schick-Wilkinson Sword Division and assistant general counsel for marketing at Unilever United States. He earned his bachelor’s degree from Harvard College and his law degree from Columbia University.
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