One of AFDO’s greatest concerns with the use of the term “natural” is that consumers may interpret a food labeled as natural to be safer or healthier for them to consume.  We feel it is critical to maintain the current integrity of the term’s use, and additional educational and outreach efforts must be undertaken to ensure that the terms “natural” and “safe” or “healthy” are not synonymous and bear no direct relationship to one another. 

In addition, USDA/FSIS will need to take a close look at each and every type of processing and make a determination as to whether or not the natural character of the product has been significantly altered. There are modern methods of food processing that do not alter the fundamental character of foods.  The term “natural” should not be, in any way, directly associated with new processing methods for assuring food safety since the food must already be safe. Again, we recognize that limiting the types of food processing a “natural” food may undergo could actually compromise food safety, because it may discourage a company from using these newer (and presumably safer) techniques; however, we do not believe this is an acceptable reason for broadening the definition of “natural.”

Additional comments from AFDO are as follows:

1)      Meat and poultry products that claim to be “natural” or “all natural” should not be subject to excessive processing. USDA/FSIS will need to clearly define what “minimally processed” means in any rule-making. Traditional ways of cooking or processing should, in our opinion, be permitted. Accommodations should not be made, however, for food processing and packaging techniques that enhance shelf-life and which may influence safety. The term “natural” is simply a marketing technique, but one that can be very misleading to the public.

2)      Certain new processing techniques, such as steam pasteurization and high-pressure processing, may be acceptable as long as the product itself is not significantly changed. Modified Atmosphere Packaging should be acceptable if the gases utilized are from a “natural” source and does not influence color retention (i.e. carbon monoxide).

3)      With respect to formal comments and studies that might exist, we would recommend that USDA/FSIS closely examine the official comments submitted in response to USDA’s development of the National Organic Program. Many of those comments deal with the issue of what should be considered “natural.”

4)      As previously stated, food safety and use of the term “natural” should not be confused.  Although there are situations where newly developed natural or minimally processed foods may not be considered as safe as similar products that have undergone further (or different) processing, labeling of a these products as “natural” is a marketing issue.  If a company chooses to cater to consumers who wish to have minimally processed foods with few or no preservatives, then both the company and the consumer are well aware of what that means to them.  Customers of health food stores may believe in few or no preservatives, and these stores will market only foods that meet their customers’ definition. Certain newer methods of processing that change the characteristics of the food should not be permitted for foods labeled as “natural”, regardless of the circumstance.

5)      Similarly, products that are “natural” are not necessarily a healthy(ier) product.  Fat in the marbling of a steak is certainly “natural” but not considered a healthy source of protein.  For this reason and that above, we feel that it is critical that USDA enhance its efforts to better clarify the use of the term and what it does and does not confer.

6)      AFDO believes that there is a great deal of confusion among consumers regarding the definitions of terms such as “natural,” “free range” and “hormone free”, due in part to the lack of regulation for these terms. Terms such as “enhanced” also present a problem. While some may consider salt-based preservatives natural, they do not consider the injection of this solution into poultry as a natural phenomenon. The easiest approach may be to consider something “natural” only when it is lacking any additives or preservatives. This should include solutions used solely to increase the amount of water or moisture in a product. Water chilled poultry may take in as much as 8% water, and in our view, should not be considered natural.

AFDO appreciates the opportunity to comment on this important matter. Government officials routinely advise consumers to “read the label” of food products when making their choice of what to consume and what may or may not be beneficial for them. It is incumbent upon us to assure that these labels are truthful and fair, and that consumers can be confident in the food choices they make.

Respectfully,

Charlene Bruce, President
Association of Food and Drug Officials