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A food product supplier has said:

Flavours are sold and marketed as natural if they are derived from the actual source. We use vanilla and chocolate flavours extracted from vanilla pods and cocoa beans.

Is this legally correct?

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What are the parameters of ingredients which may be legally listed as natural flavourings in the UK?

The use of the word "natural" on food labelling falls within Regulation (EC) No 1334/2008, as amended by the Food Additives, Flavourings, Enzymes and Extraction Solvents (Amendment etc.) (EU Exit) Regulations 2019

Article 16 Specific requirements for use of the term ‘natural’

1.If the term ‘natural’ is used to describe a flavouring in the sales description referred to in Article 15(1)(a) the provisions of paragraphs 2 to 6 of this Article shall apply.

2.The term ‘natural’ for the description of a flavouring may only be used if the flavouring component comprises only flavouring preparations and/or natural flavouring substances.

3.The term ‘natural flavouring substance(s)’ may only be used for flavourings in which the flavouring component contains exclusively natural flavouring substances.

4.The term ‘natural’ may only be used in combination with a reference to a food, food category or a vegetable or animal flavouring source if the flavouring component has been obtained exclusively or by at least 95 % by w/w from the source material referred to.

The description shall read ‘natural “food(s) or food category or source(s)” flavouring’.

5.The term ‘natural “food(s) or food category or source(s)” flavouring with other natural flavourings’ may only be used if the flavouring component is partially derived from the source material referred to, the flavour of which can easily be recognised.

6.The term ‘natural flavouring’ may only be used if the flavouring component is derived from different source materials and where a reference to the source materials would not reflect their flavour or taste.

For the use of the word "flavouring" see:

Article 15 General labelling requirements...

1... packaging or containers shall bear the following information:

  • (a) the sales description: either the word ‘flavouring’ or a more specific name or description of the flavouring;

Note that although Article 15 is for the General labelling requirements for flavourings not intended for sale to the final consumer, those that are intended for sale to the final consumer are to be included specifically when the word "natural" is used by virtue of:

Article 17 Labelling of flavourings intended for sale to the final consumer

...

  1. If the term ‘natural’ is used to describe a flavouring in the sales description referred to in Article 15(1)(a), Article 16 shall apply
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    Is it me or is that definition circular? "The term ‘natural flavouring substance(s)’ may only be used for flavourings in which the flavouring component contains exclusively natural flavouring" gets one no closer to what makes something natural?
    – User65535
    May 26 at 20:12
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    That provision seems to prohibit the inclusion of unnatural additives or adulterants. The definition of "natural" is at Art 16(4).
    – Rick
    May 26 at 20:22
  • @User65535 I was thinking the same thing.
    – Joseph P.
    May 26 at 21:12
  • So, is the suppliers' (considerably more succinct) explanation of the law accurate then or not? It seems like maybe yes, but I'm still not sure.
    – Joseph P.
    May 26 at 21:13
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    @JosephP. To me, it appears potentially accurate but wholly incomplete if the intent is to demonstrate their compliance with the law. It may be just be marketing, supported by whatever else is on the label to complete the regulations.
    – Rick
    May 27 at 6:30

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