Throughout the ages, man has been faced with difficult choices: Chocolate or vanilla? Yankees or Mets? Soup or salad? However, these all pale against today’s biggest dilemma: Organic or natural?
The battle begins
USDA’s Agricultural Marketing Service, which oversees the National Organic Program (NOP), published the final rule on national organic standards on Dec. 27, 2000. USDA’s Organic Standards asserts that organic and natural are not the same thing. “Natural” suggests that products have been minimally processed and are free of synthetic ingredients. Products labeled as “organic” have been certified as meeting USDA organic standards.
The website for the Organic Trade Association (OTA), Greenfield, MA, provides its perspective on organics: “Organic food production is based on a system of farming that maintains and replenishes soil fertility without the use of toxic and persistent pesticides and fertilizers. Organic foods are minimally processed without artificial ingredients, preservatives or irradiation to maintain the integrity of the food.”
Although NOP has the final word on federal organic definitions, OTA defines the practice as “an ecological production management system that promotes and enhances biodiversity, biological cycles and soil biological activity. It is based on minimal use of off-farm inputs and on management practices that restore, maintain and enhance ecological harmony.”
OTA goes on to assert that “natural” refers to the end product, one that is minimally processed. According to the association: “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.” OTA also states that organic products might also be considered natural, although that is not always the case, as noted in a 2007 commentary submitted by Tom Hutchenson, regulatory and policy manager, OTA: “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 ingredients 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).”
Holly Givens, public affairs advisor, OTA, adds: “All food and beverage products sold in the United States as organic must meet or exceed federal regulations for those products, no matter where in the world the ingredients or product originated. In general, products labeled as organic would be considered natural, but products labeled only as natural do not meet organic standards.”
In the quest for a definition of “natural,” the official statement from FDA explains that, “the term ‘natural’ has not been defined in FDA’s law (the Federal Food, Drug and Cosmetic Act) or in FDA’s regulations.” The agency issued a Guidance for Industry called “A Food Labeling Guide,” in April 2008, that makes no reference to the word natural other than how it is used in colors. On July 3, 2008, FDA issued a letter to the Corn Refiners Association, Washington, D.C., regarding the use of the term natural that said, in part, “our longstanding policy on the use of the term ‘natural’ is that ‘natural’ means that nothing artificial (including artificial flavors) or synthetic (including all color regardless of the source) has been included in or has been added to a food that would not normally be expected to be in the food. Additionally, we stated that we do not restrict the use of the term ‘natural’ except on products that contain added color, synthetic substances and flavors as provided in Title 21 of the Code of Federal Regulations (CFR), section 101.22.”
The brouhaha regarding the lack of a clear definition for the term “natural” was brought to a head in a 2008 court case, in which Stacy Holk filed a federal suit against the Snapple brand, alleging that the use of the term “natural” on drink labels was deceitful, because the drinks contained high fructose corn syrup (HFCS), a “highly processed sugar substitute” created through “enzymatically catalyzed chemical reactions in factories.” U.S. federal judge Mary Cooper rejected the claim, explaining that the discrepancy stems from the lack of a clear definition of “natural” from FDA.
Then, on July 8, 2008, FDA issued a statement concerning the use of the term natural for products containing HFCS. “Upon careful review of the manufacturing process for high fructose corn syrup, the FDA found that HFCS can be labeled natural,” states Audrae Erickson, president, Corn Refiners Association. “HFCS contains no artificial or synthetic ingredients or color additives and meets FDA’s requirements for the use of the term ‘natural.’ HFCS, like table sugar and honey, is natural. It is made from corn, a natural grain product.”
Meat and poultry products follow another set of rules. These are governed by USDA’s Food Safety and Inspection Service (FSIS), which requires these products to be free of artificial colors, flavors, sweeteners, preservatives and other ingredients that don’t occur naturally in the food. In addition, “natural” meat and poultry must be minimally processed by methods that do not fundamentally alter the raw product. The label also needs to explain the use of the term natural, such as “no artificial ingredients.”
Walter Crawley, director of marketing, Kerry Ingredients and Flavours, Beloit, WI, notes there is some confusion surrounding the meaning of “natural,” as it can “vary based on the marketer’s definition,” he says. “For example, the phrase ‘all-natural’ can mean just about anything; it actually has no nutritional meaning whatsoever and isn‘t truly regulated by the FDA. Some marketers may define a natural flavor as, ‘all flavoring components are natural.’ Other marketers may define a natural flavor as, ‘all flavoring and nonflavoring components are natural.’”
Whole Foods Market, Austin, TX, is often a beacon in the industry for those unsure about which natural products are truly natural. “Because of the variances and lack of definition by the FDA, many suppliers and manufacturers refer to the Whole Foods guidelines as to what determines natural,” says Beth Fulmer-Boyer, vice president of sales, Asoyia, Iowa City, IA, referring to the grocer’s list of standards and ingredients that determine whether it will sell a product in the chain’s stores.
Labeling and certification
While there are many acceptable definitions of “organic” and “natural,” just who is in charge of enforcing and regulating certified organic claims? The Organic Food Production Act of 1990 established the standards for production, processing and certification of organic food. The National Organic Standards Board (NOSB) is the group responsible for developing guidelines and procedures to regulate organic crops. The NOSB members, who are from all four U.S. regions, assist the USDA Secretary in developing the standards for substances to be used in organic production, as well as advising the Secretary on other aspects of implementing the NOP.
NOP is a federal regulation created by USDA. The program is responsible for developing and implementing organic standards, as well as accrediting state agencies and private organizations to certify organic producers and handlers. There are four types of organic claims for labeling, according to USDA: “100% Organic,” “Organic” (95% organic ingredients), “Made with Organic (specified ingredients or food groups)” (at least 70% organic ingredients) and products containing less than 70% organic ingredients. (For complete details on these designations, see the NOP website, ams.usda.gov/nop.)
Food grown in any other country can be sold as organic in the United States, provided that all organic standards are followed and the organization is certified by a USDA-accredited official.
Since 2002, it is a federal offense to label any food product as “organic” unless it has been certified. In order for a product to become certified, “a grower or handler seeking organic certification submits an organic farm plan or organic handling plan to a USDA-accredited private or state certification program,” according to OTA. The organic plan must detail all current growing or handling methods, and any materials that will be used, as well as cover future intentions and improvements to all areas of production. The certification agency is also responsible for performing annual on-site inspections of each farm or operation in its program. OTA also notes that retailers aren’t required to be certified. NOSB, however, recommends certification for retailers that engage in activities that qualify them as handlers (i.e., repacking bulk products, such as dry beans or grain).
So what’s better: natural and organic? or conventional? USDA makes no claims that organic food is safer or more nutritious than conventionally produced food. OTA, on the other hand, states that organic foods are better for you, reasoning that organic foods are higher in nutrients. Kerri Palmer, senior account executive, RMD Advertising, Columbus, OH, who works with Dei Fratelli, Toledo, OH, which uses organic tomatoes in its sauces, agrees that organic is healthier. “Typically,” she says, “what we find is that there’s probably twice as much vitamin C” in these sauces compared to conventional counterparts. “Each one of our products is going to have close to 40% of your daily recommended value of vitamin C,” she says. “As for vitamin A, it has 20% of your daily requirements. There’s also some potassium in there, and some iron.”
Organic products are also “spared the application of toxic and persistent insecticides, herbicides, fungicides and fertilizers,” according to OTA. “In the long run, organic farming techniques provide a safer, more-sustainable environment for everyone.”
“People who prefer and/or seek organic and natural foods are generally educated, but often not expert technically. They are concerned about the natural and/or safe condition of the food they consume,” says Terri Volpe, technical consultant, Asoyia. “They are very interested in health and wellness and are generally well-read, but often are familiar with anecdotal and popular information, not always technically correct information.” She adds that many women become interested in natural and organic foods for their children.
“What sets organic purchasers apart is the value they place on what organic products represent—a way of farming that takes care of the planet, and processing that maintains the integrity that began on the farm,” says Givens.
Karen Manheimer, vice president, natural products, Kerry Ingredients and Flavours, believes that recent food-safety scares have pushed consumers in the organic direction. “Originally a very niche group, now more and more people are picking up some type of natural or organic product while grocery shopping,” she says.
While going organic might be perceived as better for one’s health, it’s not so great for those on a budget. A 2008 article from CNNMoney.com, “The High Price of Going ‘Organic,’” cited a 2008 survey from consulting firm WSL Strategic Retail, New York, that found the higher cost of organic products vs. mass-market alternatives is a deterrent for some consumers. The article stated that, on average, organic products sell for as much as 50% to 100% more than nonorganic alternatives.
For example, “organic peanuts and peanut-derived ingredients are about double the price of nonorganic peanut products,” notes Bruce A. Kotz, vice president of specialty products, Golden Peanut Co. LLC, Alpharetta, GA.
All about oils
In the manufacturing industry, oils can be certified as organic. “It is usually focused on whether the product is made from non-GMO sources and whether it is processed in a way that does not involve chemicals,” explains Fulmer-Boyer, noting that the grain also needs to be identity-preserved. To avoid potential cross-contamination, the product would have to be produced in a facility that is exclusively non-GMO.
“We monitor the peanut fields and farmer closely,” says Kotz. “The raw peanuts are shelled within our own plant. Therefore, the peanuts we use for the further-processed organic peanut ingredients, such as roasted aromatic peanut oil, are monitored closely.”
Fats and oils undergo several commercial refining processes to remove water, carbohydrates, proteins, pigments, phospholipids and free fatty acids. This improves shelf-life and sensory properties. The four typical processing steps include: extraction, neutralization, bleaching and deodorization.
Several methods can be used to process oil and keep it organic. The same methods can also be considered natural when used on nonidentity-preserved or GMO crops. “We do mainly hexane extraction for our oil, but have initiated using a supercritical CO2 extraction—a low temperature process that will extend the shelf-life stability of the oil,” Volpe explains. “We are looking also at a product made from supercritical CO2 extraction that does not have to be refined, bleached or deodorized. We will investigate its stability in a number of applications very shortly.”
Colorful lines in the sand
For colors, natural and organic are quite different, according to Byron D. Madkins, director of food and beverage development and applications-color, Chr. Hansen, Inc., Milwaukee, WI. “Natural colors are those colors that are derived from sources in nature—e.g., plants, fruits, vegetables—and that are regulated as exempt from certification,” as outlined in 21 CFR Part 73, he says.
Synthetic colorants, such as FD&C Red 40 or FD&C Yellow 5, require individual batch certification by the FDA before they can be sold into the marketplace, Madkins explains. FDA tests for, among other things, purity, salts and heavy metals, and it certifies every batch that is manufactured and subsequently sold in the United States. “The exempt colors, or natural colors, are, in fact, exempt from this protocol,” he says. One caveat: Unless the color is natural to the food product itself, FDA requires the product to be labeled as “artificially colored” (21 CFR 101.22).
Madkins notes that natural colors that are certified organic require proper documentation and approvals before the seed, growth, harvest, extraction, processing and final production of the natural color. No synthetic colors can be deemed organic, according to the regulations.
The phrase “nature identical,” identical chemically to the form found in nature, is making waves in the color community. “This is the phrase that is used mostly with the color beta carotene,” Madkins explains. “This colorant, even though most of the forms used in the food industry are actually synthetically manufactured, was petitioned to the FDA as being nature identical. This designation was approved by the FDA, and beta carotene is regulated as an exempt colorant in 21 CFR Part 73, with the other colorants that are from natural sources.”
Cost is always a top consideration for color formulations. “While natural colors will probably never be as cheap as synthetic colorants, the actual cost in use in using natural colors in place of synthetic colors has dramatically improved as compared to many years ago,” says Madkins. Using natural colors provides many benefits. “They allow for a cleaner ingredient declaration or label for the finished product,” he says. “In addition, with the use of natural colors, the shade range is also widened.”
From a texturant perspective, natural and organic are two different things, notes Cheryl Austin, technical information and compliance manager, Cargill Texturizing Solutions Quality Assurance, Wayzata, MN. “A natural, or naturally sourced, ingredient may be suitable for use in organic foods, but not on the basis of its ‘naturalness’ alone,” she says. “An ingredient that may be suitable for use in organic foods may not qualify as a natural foodstuff,” as defined by her company. She adds that “natural” describes a trait or characteristic, whereas “organic” describes a process from an ingredient point of view.
Gums, however, are often derived from a natural source, notes Frances Bowman, marketing specialist, TIC Gums, Inc., Belcamp, MD. “A majority of gums come from all-natural sources, such as tree exudates, seeds and seaweed,” she says. “These gums include gum acacia, guar gum, locust bean gum, alginate, agar and inulin. Gums that have been grown, harvested and processed according to organic regulations can be labeled organic. Many of the regulations are in place to ensure that the ingredient can be traced from the source to the finished form.”
In order for nonorganic products to be used as ingredients or processing aids in organic products, the nonorganic products must also meet the requirements of NOP regulation §205.105 (non-GMO, no sewage sludge and nonirradiated). “Where nonorganic agricultural products are used as ingredients or processing aids in organic and made with organic products—with usage levels at up to 5% and 30%, respectively—the original organism that produced the product must not be genetically modified,” Austin says. “For example, for unbleached soy lecithin, the soy plants must not be from genetically modified stock.” When nonagricultural products are used as ingredients or processing aids, the product must be “free from modified DNA and/or the proteins from genetically modified DNA,” she says. “And, if microorganisms are used to produce the product, the microorganisms must not be genetically modified.” For example, in maltodextrin production, the microorganisms used to produce them must not be genetically modified.
The organic industry has exploded in the past few years, growing 21% to reach $17.7 billion in 2006, according to a 2007 survey conducted by Packaged Facts, Rockville, MD, with an anticipated 18% growth per year for 2007 through 2010.
Putting the “O” in Hydrocolloids
Following is a list of “synthetic texturants” approved by the National Organic Program (NOP) for use in organic products.
Texturizers suitable for use as nonagricultural (nonorganic) substances:
• Pectin—low-methoxyl-type pectin is an allowable synthetic substance;
• Xanthan gum—an allowable synthetic substance;
• Carageenan—allowable as a nonsynthetic substance.
Texturizers suitable for use as nonorganically produced agricultural products:
• Food starches—only native, or unmodified, starches, derived from non-GMO sources, are suitable for use in “organic” (5% max usage level) and “made with organic” foods;
• Locust bean gum—commercially available in an organic form, which would preclude the use of organic-compliant forms in organic foods.
Source: Cargill Texturizing Solutions, Wayzata, MN