Shoppers find the “natural” label on foods confusing

May 10, 2016

Division of Dockets Management (HFA – 305)

Food and Drug Administration

5630 Fishers Lane

Room 1061

Rockville, MD 20852

Docket No. FDA-2014-N-1207: Use of the term “Natural” in the labeling of human food products, Request for information and comments

To whom it may concern:

PCC Natural Markets is the largest retail grocer in the United States owned by consumers. We value the opportunity to comment on use of the term “natural.”

Our 10 stores in western Washington are owned by more than 56,000 member-owner households and generate more than $250 million in annual sales. Our mission and operations are designed to ensure “members and patrons are well educated in matters of healthful food.” We believe our shoppers are some of the best educated grocery shoppers in the country.

Since USDA National Organic Standards were implemented in 2002, we’ve seen increased use of the term “natural” on conventional products to confuse, not inform consumers, and to greenwash products that are far from what consumers would consider suitable. Research confirms consumers nationwide are confused. Foods labeled “natural” typically do not deliver what consumers think they’re buying.

A 2010 survey by The Hartman Group in Bellevue, Wash. found a majority of respondents across the country believe “natural” implied “absence of pesticides” and “absence of herbicides.” Sixty-one percent believed “natural” implied or suggested the “absence of genetically engineered foods.”

We also see Consumers Union surveyed consumers in December 2015, finding more than half usually seek out products with a “natural” label, often in the false belief that they’re produced without genetically engineered organisms, artificial hormones and pesticides, or other artificial ingredients. At least 60 percent believe “natural” claims on processed or packaged foods mean the food was produced without pesticides, without artificial materials or chemicals, without artificial additives or colors, and without genetically engineered (GE) organisms. Consumers Union also found at least 80 percent of consumers believe the term “natural” should meet those criteria.

These consumer assumptions and beliefs are so far from the reality of what “natural” claims actually allow that we believe FDA has the responsibility and authority to ban the term “natural” under the false and misleading labeling provisions of the federal Food, Drug and Cosmetic Act (21 USC §343 (a)(1). If FDA determines it cannot or will not ban use of the term “natural” on food labels, it should define “natural” through formal rulemaking to be consistent with consumer beliefs and expectations. We ask FDA to establish a third-party verification system to enforce any new standard and to deem any product “misbranded” if it does not meet the criteria.

We posed FDA’s questions about “natural” directly to our members for commentary. The shopper comments we received support both the Hartman Group and Consumers Union findings consistently. They make it clear FDA should address how food is produced, not just ingredients and processing techniques when defining “natural” food label claims. Here is a sampling:

1. Do consumers associate, confuse, or compare “natural” claims to organic?

“ABSOLUTELY! Even with my vast experience on the subject, in the grocery store I find myself thinking of ‘natural’ as organic. Such stretching of the term undermines the basic language issue of clear and truthful communication with consumers so that they can make informed decisions.”

“I think there’s enormous confusion amongst consumers about what these labels mean.”

“With no official definition, how can folks not be confused – each has to make up their own definition of what they think or hope it might mean.”

2. Do you believe some consumers consider “natural” and organic to be the same, or is “natural” perceived to be better, or not as good as organic?

“From personal experience, I know the terms are considered synonymous by many. Some consumers will consider the ‘natural’ designation to be superior because they are ignorant of legal limitations entailed with use of the term ‘organic’ …”

“The terms are not well understood by consumers and, to a large degree, mainstream grocery businesses are happy to keep the terms confusing and the shoppers confused. See for example, Kroger’s line of products called ‘Simple Truth,’ where it mixes certified organic products with non-organic products. Even the customer service staff at QFC are confused by that: I once had two of them swear to me that a product was organic because it had the Simple Truth packaging but I defied them to point to the word ‘organic’ anywhere on the package and they could not.”

“Consumers assume natural to mean it is organic. It is confusing. A meaningful ‘natural’ label should, at an absolute minimum, mean the product is organic.”

“Most people are confused and believe there to be some relationship to organic foods or better. Please be clear the Grocery Manufacturers Association’s bid to label GE foods ‘natural’ should be denied because of the confusion that already exists …”

3. Should certain production practices, such as genetic engineering, mutagenesis, toxic pesticides or animal husbandry practices be a factor in defining “natural?”

“Yes, certain practices should disqualify products from being labeled ‘natural,’ including genetic engineering, mutagenesis and use of toxic pesticides. Anything that’s genetically engineered is – by definition – not natural. It didn’t occur in nature: it was engineered in a laboratory.”

“Anything produced that is for human consumption that is altered, engineered, affected by pesticides or herbicides, impacted by hormones, antibiotics, steroids, or growth stimulators should be excluded.”

“Practices such as genetic engineering, mutagenesis, use of toxic pesticides should not be allowed under the label ‘natural.’”

“Certainly. The entire reason for the debate in terminology is that consumers hope to make informed decisions about health. The above mentioned practices are demonstrably unhealthy, so the GMA effort to trick consumers with terminology instead of being honest (labeling) or changing unhealthy practices is detestable.”

“I have a hard time imagining the word “natural” can have a meaningful definition in relation to food. It seems to me the best way to describe foods is to use more exacting terms rather than vague terms … It seems to beg for confusion. ‘Non GMO’ is clear. ‘No Pesticides’ is clear. ‘No chemical additives’ is clear.”

4. Should animal products labeled “natural” require the animals are raised without growth promotors for feed efficiency or weight gain, or sub-therapeutic antibiotics?

“Yes. Such treatments are unnatural.”

“Animal products labeled ‘natural’ should be raised without growth promoters for feed efficiency or weight gain, and without the use of sub-therapeutic antibiotics.”

“If we must have the term ‘natural’ mean something in relation to food, it definitely should NOT permit the use of growth hormones or antibiotics.”

“YES. Besides being dishonest, feed efficiency for weight gain is efficient only with regard to marketing profits. It has no relevance to health concerns — the language is just another ploy by GMA to confuse consumers.”

5. Should animal products labeled “natural” require the animals are raised on pasture?

“Yes, always.”

“Animal products labeled ‘natural’ should mean the animals are raised on pasture. And for beef, that means entirely pasture raised, not ‘pasture raised/grain finished,’ which means the same old feedlots for the last portion of the cows existence.”

“Again, I suggest ‘natural’ is not an appropriate word – ‘pasture raised’ and a definition of the percent of time spent on pasture is understandable and should not be confused.”

6. For a multi-ingredient food, what type(s) of ingredients should disqualify it from bearing a “natural” claim?

“I’m not sure and just confirms my belief that ‘natural’ is a useless term.”

“Any ingredient that itself could not bear the ‘natural’ claim: anything GE, artificial, produced with toxics, etc.”

“Any ingredient that is not organic should be considered unnatural. I repeat, the objective on the part of GMA to employ the term ‘natural’ is to obscure meaning and to confuse consumers.”

7. Should pasteurizing, irradiating and hydrolysis be allowed in “natural” foods?

“Pasteurizing is acceptable but not hydrolysis.”

“Natural to us means no irradiating or hydrolysis processes.

“NO. All of the above processes are not natural.”

“No, and again shows why ‘natural’ doesn’t make sense.”

8. What can be done to ensure consumers have a consistent and accurate understanding of “natural” labels that is not misleading?

“Declare is it a meaningless term as it relates to food and prohibit the use of it on food labels”

“All grocery stores should be required to post the definitions in the stores and train their staff to know them.”

“Require manufacturers to tell the truth and adhere to the spirit of the law. If manufacturers are foisting unhealthy products on consumers, at the very least they should not be allowed to obfuscate the issues by using terms like ‘natural’ to confuse consumers. FDA should require manufacturers to have and maintain a degree of integrity in their advertising. Also, FDA should promote the idea that doing the right thing can also be profitable and cost effective.”

“To avoid confusion, the ‘natural’ label should be tough and meaningful by incorporating all of the above!”

“The FDA needs to stop being influenced by politicians and industry and adopt a uniform definition of the word ‘natural’ just as it has done with the word ‘organic.’”


We urge FDA to establish a standard for food labeled “natural” that’s consistent with consumer expectations illustrated by the above surveys and comments. Clearly, consumers expect “natural” refers not just to ingredients and processing methods, but also the methods used to produce food.

Consumers expect “natural” foods are produced without synthetic pesticides or genetic engineering, that livestock are raised outdoors with pasture, without growth promotors for feed efficiency or weight gain, or sub-therapeutic antibiotics, and no irradiation or hydrolysis. These and other production methods already are addressed thoroughly by USDA’s organic standards.

Therefore, to bring the “natural” label claim into alignment with consumer expectations, FDA should require all food labeled “natural” to be certified organic as a baseline. In fact, the Hartmann Group and Consumers Union surveys found most consumers already believe “natural” and “organic” are largely synonymous. Our member/owner consumer comments were consistent with that position.

We urge FDA to establish organic standards as the baseline for defining “natural,” using the existing structure of USDA certification and enforcement, without having to develop a new standard from scratch. In this way, USDA organic standards are clarified and strengthened to reflect what consumers actually expect.

However, since some organic foods include artificial ingredients, not all organic foods would meet consumer expectations for “natural.” Organic standards set a baseline, but only organic foods without artificial ingredients meet consumer expectations for “natural” claims.

FDA already has stated in the Federal Register that “natural” means nothing artificial or synthetic has been included or added to a food. Yet we still see the term “natural” on foods with artificial ingredients, misleading consumers every day. This indicates FDA must codify a definition for “artificial” and exclude foods containing ingredients produced artificially with genetic engineering, synthetic biology, genomic editing, or nanotechnology.

We thank FDA for the opportunity to comment and urge the agency to move quickly to formal rulemaking to correct the deceptive and false use of “natural” claims.


Trudy Bialic

Director, Public Affairs

PCC Natural Markets

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