"Natural Flavors": What the Term Legally Means

"Natural flavors" is one of the most common entries on US ingredients lists, and one of the least transparent. The term has a specific legal definition from the FDA, but it can cover a wide range of substances, and the label doesn't have to say which ones are used. This guide explains what the definition includes, how natural and artificial flavors differ, and what you can and can't learn from the label.

The legal definition

The FDA defines natural flavor in its regulations at 21 CFR 101.22(a)(3). In plain language, a natural flavor is an essential oil, oleoresin, essence or extract, protein hydrolysate, distillate, or product of roasting, heating, or enzyme action that contains flavoring substances derived from:

• a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf, or similar plant material; or
• meat, seafood, poultry, eggs, or dairy products; or
• fermentation products of any of these,

and whose main purpose in the food is flavoring rather than nutrition.

Two points stand out. First, the definition is about the source of the flavor, not about how much it's processed. A natural flavor can be extracted, concentrated, heated, or fermented in a lab and still qualify. Second, the source can be animal-based, which matters for people who follow vegetarian or vegan diets.

Natural vs artificial flavors

Under the same regulation, an artificial flavor is any flavoring substance that isn't derived from the sources listed above. The difference is where the molecules come from, not what they are.

Vanillin, the main flavor compound in vanilla, is a good example. It can be extracted from vanilla beans, produced by fermentation, or synthesized from other starting materials. The molecule is identical, but depending on the source, it may be labeled as a natural or an artificial flavor. For that reason, "natural" on a flavor doesn't by itself mean healthier or safer than "artificial." Both kinds of flavoring substances must be approved food additives or generally recognized as safe (GRAS) for their intended use; many have been evaluated through the flavor industry's GRAS program, with the FDA able to review and challenge those determinations.

What "natural flavors" can hide

Many ingredients, one name

A flavor is often a blend of dozens of individual compounds. The FDA allows these to be listed simply as "natural flavor" or "natural flavors" without naming each component, which protects manufacturers' formulas as trade secrets.

Carriers and processing aids

Flavor preparations may also contain small amounts of solvents, carriers, emulsifiers, or preservatives that help deliver the flavor. When these are present only at insignificant levels and have no technical effect in the final food, they generally don't have to be listed separately.

Allergens are the exception

If a natural flavor contains any of the nine major allergens, such as milk, soy, wheat, or sesame, federal allergen labeling law requires the allergen to be declared, either in the ingredients list or in a "Contains" statement. The rest of the flavor's composition can stay undisclosed.

Animal-derived sources

Because natural flavors can come from meat, seafood, eggs, or dairy, a product listing "natural flavors" isn't necessarily vegetarian or vegan unless the manufacturer says so. Some companies disclose the source on request or use a vegan certification.

How flavor names appear on the front

FDA rules also govern how a flavor is described on the front of a package when the label features a characterizing flavor like strawberry or vanilla:

• "Strawberry yogurt" suggests the flavor comes mainly from strawberries.
• "Natural strawberry flavored" or "strawberry flavored" means the flavor comes from natural flavoring, and not necessarily from the fruit itself.
• "With other natural flavors" means some of the strawberry taste comes from natural flavors derived from something other than strawberries.
• "Artificially flavored" means artificial flavor was used for the characterizing flavor.

Keep in mind that the broader word "natural" on a package, as in "all natural," is a different matter. The FDA has not formally defined it for foods and has a longstanding policy that it means nothing artificial or synthetic has been added that would not normally be expected in the food.

Organic products

Products certified under the USDA National Organic Program can also contain natural flavors, but organic rules add limits: the flavors used in organic foods can't be produced with synthetic solvents, synthetic carrier systems, or artificial preservatives. The composition still doesn't have to appear on the label.

Should you avoid natural flavors?

For most people, there's no evidence that natural flavors as a category are harmful at the levels used in food. The more useful question is what the presence of flavorings tells you about the food. Flavorings of any kind are common in highly processed products, where they help replace taste lost in processing. Seeing "natural flavors" near the end of a short ingredients list is very different from seeing it in a long list alongside added sugars, colors, and sweeteners.

If you have a food allergy, follow a vegan or religious diet, or react to specific substances, contacting the manufacturer is the only reliable way to learn what a natural flavor contains.

How to use this on myfoodfact.com

• See which products list the term on our natural flavors ingredient page.
• Compare with another common flavor ingredient on our MSG ingredient page.
• Understand where flavorings fit in food processing in our guide to ultra-processed foods and NOVA.
• Check how hidden allergens must be declared in our guide to the 9 major allergens.

The bottom line

"Natural flavor" has a precise legal meaning under 21 CFR 101.22(a)(3): the flavoring must come from plant or animal sources, or their fermentation, and its main role is taste rather than nutrition. It doesn't mean the flavor is minimally processed, plant-based, or different in chemistry from an artificial flavor, and the label doesn't have to reveal the components. Allergens are the key exception, since they must always be declared.

This guide is for general information and is not medical advice. If you have a food allergy or sensitivity, check with the manufacturer and your health care provider when a label doesn't answer your question.