The United States Food and Drug Administration (FDA) is seeking comments on the use of the term natural in the labeling of human food products. This is an issue of great importance to Certified Naturally Grown and the broader sustainable agriculture community.
As you know, the GMO-friendly processed food manufacturers have played fast and loose with the term natural, deploying it on nearly any food product they wish, and often gaining an undeserved marketing advantage. Many people assume that processed foods labeled natural don’t contain GMO’s. Reasonable people interpret it to mean that there are no artificial or synthetic ingredients or processing aids. But in reality, the FDA places very few limitations on the use of natural.
The comments and experiences of Certified Naturally Grown members and friends can provide valuable perspective to FDA as it considers how to approach this situation. Your input is particularly important in light of some rather striking petitions submitted to FDA regarding how natural should be defined or regulated. The public comment period ends May 10, 2016.
One consumer group has petitioned the FDA to ban the term "natural" on food products altogether, or alternatively, for it to be heavily regulated, like the term organic. Coming from a very different perspective, the powerful processed food industry group, the Grocery Manufacturers Association (GMA), has petitioned the FDA to explicitly allow foods derived from biotechnology (containing GMOs) to be labeled natural.
Misleading marketing should not be allowed to continue. There is a role for government to play combating deceptive use of the term natural by food processors and manufacturers. But to ban the term natural goes too far. Natural is a word in the English language that is often used responsibly and meaningfully, particularly within local and regional food systems. We therefore adamantly oppose that the word be taken out of circulation, or that it be heavily regulated like the term organic.
The FDA is only in the fact-gathering phase, not rule-making, so no big change is on the near horizon. But we should take this period of public comment to call for protecting the integrity and the use of the term natural, and in particular to ensure that the certification programs offered by CNG are not banned or regulated.
It’s not likely that FDA would take actions that would disrupt a successful and long-established program like Certified Naturally Grown, but comments from CNG members and supporters will help ensure a positive outcome for the organization, and for all local and regional food producers who wish to continue to use the word natural responsibly in marketing their products.
The expertise and authority of FDA is suited to regulating food processing, rather than agricultural production, which is within the USDA's purview. So we would strongly discourage FDA from attempting to regulate production claims, such as "naturally grown". But within the realm of processed foods, we recommend FDA take steps to combat the deceptive and misleading use of the term natural. FDA should establish robust enforcement measures against companies that use the term natural in a way that is misleading or deceptive. Products bearing the term natural should conform to the public's common sense expectations for what the term means.
Please submit your comments to FDA this week! The deadline is next Tuesday, May 10. Even a short comment can be helpful. To make commenting easier, you may refer to the template below.
Click here to submit your comments, either online or via paper mail.
If you're curious to dig deeper, click here to read FDA's announcement and background information.
Thank you very much for being engaged in our grassroots initiative. Together we're stronger!
Suggested comment template
To Whom it May Concern:
I'm writing regarding Docket No. FDA-2014-N-1207 on FDA's regulation of the term "Natural" for food products.
[Describe your farm (what types of crops, production methods, and how you market) and/or your relationship to the local and regional food system. If you’re a CNG producer (past or present) indicate how long you’ve been a member (or were a member), what certification/s you hold/held, and what you value about being a part of CNG.]
Natural is a word in the English language that is often used responsibly and meaningfully, particularly within local and regional food systems. We therefore adamantly oppose that the word be banned, or that it be heavily regulated like the term "organic" has been.
Any regulation or definitions put forth by FDA should pertain to processed foods, not agricultural production methods. In particular, we call on FDA to combat the deceptive and misleading marketing of foods as "natural" when they contain GMOs, or artificial and non-food ingredients.
Your Farm Name and/or Organizational Affiliation
Your City, State
(Note: it's optional to include your personal information within the comments themselves.)