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If a flavor ingredient (e.g. vanillin) was produced via a natural fermentation process, starting from a natural substrate (e.g. sugar) I know that it can be labelled as "natural" (at least in the US and EU).

Now my question is, suppose one were to use a recombinant organism for this fermentation, would the product vanillin be regarded as natural?

Alternatively, suppose only an enzymatic treatment of the substrate sugar was involved, however the enzyme itself was produced by a recombinant organism would this impact the natural status of the product vanillin?

A related question: If a product is made using a GM enzyme does that automatically make the product a GMO? (note the substrate is NOT a GMO in this case. Only the enzyme is.)

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    Seems like this is more about Law than Biology. Would you like me to move it there?
    – Bryan Krause
    Commented Feb 1, 2021 at 14:45
  • Agree with Bryan. This is a regulatory question, not a biology question. To my knowledge, neither the FDA nor the USDA have strict rules regarding use of "natural" in product labels, but do have some working definitions which may be applied to determine if labels are "truthful and not misleading." Those definitions likely vary between different product types (food, cosmetics, drugs, etc.). There's an FDA memo with a link to comments on the subject here (fda.gov/food/food-labeling-nutrition/…).
    – MikeyC
    Commented Feb 1, 2021 at 18:00
  • @BryanKrause Thanks. Sure, I am okay with sending it to Law SE. However, these sort of technical-regulatory questions are always tricky. Not sure if the best answers will be from lawyers or biologists! :)
    – curious_cat
    Commented Feb 3, 2021 at 7:22
  • In this case there's really no biology to the answer. A chemical is the same chemical no matter how it's created.
    – Bryan Krause
    Commented Feb 3, 2021 at 14:37
  • This depends on which legislation applies - Are you asking for the US or the slightly less permissive EU, or even a single, most likely less permissive, member state of the EU? Because for example, a chicken could be fed all "Bio" but if you treat it with Chlorine-oxide after it was butchered, it can be illegal to be imported into and sold inside the EU.
    – Trish
    Commented Feb 4, 2021 at 10:27

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