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Conceptual framework for `natural`(colours)
Dr. Dirk Cremer
Global Colour Conference
Chicago Sept 2014
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‘Natural’ …not a topic for b/w thinkers but for
those who see the shades of grey
`Natural´ claims are
– marketing claims
– subjective and emotional
– primarily not evidence based
– depend on context of use
– a story to be told
–
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used to gain competitive advantage over similar products w/o
such claim
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Degress of `naturalness` are common sense
Made from
natural
ingredients
To what
extend does it
matter
whether the
lemonade
contains
carrot extract,
beta carotene
or sunset
yellow as
colouring
principle?
Unprocessed food, no
additive use at all
((Art. 3 (2) (d) and Art.
15 reg. (EC) 1333/2008)
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Low percentage of orange
100 % fruit juice, only
E 300 and E 330 permitted, juice; an array of additives
colour additives prohibited may be used, incl. colours
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«Free from artificial colour» front of pack
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Focus of today:
‘natural food ingredient’ in
terms of a technical
definition
no finished foods,
no labelling.
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Legal definitions for flavourings, guidance for all
other foods/ingredients
• Various jurisdictions legally define `natural`for flavourings, incl. Codex
Alimentarius in CAC/GL 29-1987 on a technical level
• Common elements of relevance:
- origin /source material
- process applied
• No legal `natural`definitions for other ingredients/finished foods on
global scale
- other than to provide truthful and not misleading
information to consumer
- Codex Standard CAC/GL 1-1997 stipulates: `natural`claims to be used
in accordance with national practices
- National guidance available: UK, France, Sweden, Canada, USA
- Industry guidance: NATCOL for colours
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ISO proposal to eliminate technical barriers
•
ISO draft defines `natural food ingredients` technically, no labelling
•
Natural ingredients and foods seen as sustainable consumer trend and opportunity
for industry
•
Absence of international standard of risk for the food industry and for consumer
trust
• Growing competition between `natural` and `organic`
•
`Organic` regulated in 74 countries
• No success at Codex CCFL to find consensus on a `natural`definition
•
A trusted ISO standard could become a cornerstone to help shape an international
regulatory framework of the future
•
ISO standard of value for global players and SMEs alike
•
ISO standard could help reduce bariers in international trade
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So what does food
ingredient industry need
with regards to a
definition of ´natural food
ingredients`?
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Industry needs a balanced
`natural` standard
• Innovation/competiton naturally occurrs between
ingredients of same function: sweetness competes
against sweetness, colour against colour,….
• Innovation is towards more natural ingredients in the
natural/artifical continuum (gradual)
• Too liberal standard  discourages innovation for food
ingredient manufacturers
• Too conservative standard  discourages innovation
for the finished food manufactures
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Flexibility, case by case, no «one size fits all»
Food ingredients basket is very diverse
- agriculture derived commodities: flours, starches, cocoa,
coffee, tea, sugars, maltodextrin, edible oils/fats,…
- food additives: colours, sweeteners, antioxidants,
- nutrients: mineralic substances, vitamins, phytonutrients,
amino acids
- water, nitrogen, carbon dioxide
Perception of naturalness and what matters for assessing
naturalness differs between the various types of
ingredients
- What story to tell?
- UK and French guide differentiate foods/ingredients/additives
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Common elements in ´natural` regulations/guidance
1 Origin/source material
2 Process applied
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Key element #1 for a ‘natural ingredient’ definition:
consists of or is derived from certain sources
Plants, Animals, Minerals, Microorganisms acceptable
Water?
Air?
Codex benchmark CAC/GL 29-1987 for natural
flavours (sec. 1.2): „….vegetable or animal origin…“
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Key element #2: obtained by certain processes
Generally: Physical, enzymatic, microbiological
processes acceptable
Codex benchmark CAC/GL 29-1987: „….obtained
exclusively by physical, microbiological or enzymatic
processes from material ...or after processing…by
traditional food preparation processes“
Regulation (EC) 1334/2008: chemical modifications as
result of processing acceptable for traditional
processes only but not for physical processes per se
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`Traditional` relevant for `natural ingredients`?
Special case flavours:
Raw material
w/o flavour
Traditional
food
preparation
process*
Processed
material I
EU: Intentional chemical
modification acceptable
Physical process*
EU: Intentional chemical
modification not acceptable
* Note: processing picture incomplete; for full overview and
interpretation visit EFFA guidance at http://www.effa.eu/en
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Flavour
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Chemical reactions are neither un-natural nor artificial
per se
No life w/o multitudes of complex (bio-)chemical reactions
Simple processes (cutting, grinding, freezing) applied to a living
organism (plant material)  uncontrolled chemical reactions
Physical (e.g. extraction, heating) /traditional processes include
chemical modifications
- alkalisation of cocoa to allow wettability
(Dutch process, C J van Houten, 1830)
- cutting of onions
- caramelisation (colour or flavour formation)
- Maillard reactions
- (Re-)esterifications upon ethanolic extraction
Key question
is not whether a process is traditional or not, but
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what extend of chemical modification is considered acceptable
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`Traditional` in `natural` concept potentially obsolete
UK FSA guidance: „Natural“ means essentially that the product is comprised
of natural ingredients, i.e. ingredients produced by nature, not
the work
of man or interfered with by man. It is misleading to use the term
to describe foods or ingredients that employ chemicals to change their
composition or comprise the product of new technologies,
including additives and flavourings that are the product of the chemical
industry……(55)…non-tradional distillation …not in line with current
consumer expectation of „natural“….
Critical notion in the guidance
• No human interference acceptable unless it was s.o. in the past who…
- unkowningly (?) used products of the chemical industry (baking powder,
alkali, potash, ammonia hydrogencarbonat) and made use of chemical
reactions to produce traditional foods (Pretzels, Lebkuchen, cakes, Lutesk
fisk,…)
• Innovation cannot be natural and consumers are hostile to innovation
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- new technologies disqualify as natural, e.g. vacuum distillation
as a non-traditional distillation technique
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Processes require a qualifying principle
Processes not acceptable per se:
- too liberal
-
loss of practical relevance for assessing ingredients
What is a qualifying principle?
- USDA: not more than minimally processed (meat/poultry)
-UK FSA: render suitable for human consumption (single foods)
- Dir 2009/54/EC (natural mineral water): not alter the
composition of the water as regards the essential constituents
which give it its properties
- Reg (EC) 1333/2008 (unprocessed food): not undergone any
treatment resulting in a substantial change in the original state
of the food
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Proposal for a possible qualifying `natural`
principle for all processes
Natural ingredients are processed when
technologically needed. Processing may require to
render an ingredient suitable for human consumption,
its intended purpose of use and/or technical function
(food additives). Chemical reactions beyond those that
are inherent to a process as such are only acceptable
if they are unintentional or the particular process for
the manufacture of a specific ingredient is a
recognized traditional* process for that ingredient.
* Traditional may need be further defined or
replaced by other language qualifying what
principles shall apply for acceptability of
chemical modifications
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Positive listing of processes acceptable if certain
conditions are met
Available regulations/guidance commonly work with positive
and/or negative list of (non) acceptable processes
Positive list of acceptable processes is suitable provided
- list is an open positive list
- all processes subject to qualifying principle
- processes acceptable only on case by case basis
- processes described in sufficient detail (incl. examples) to
understand acceptability/limitations as regards the qualifying
principle
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UV treatment and the synthesis of vitamin D
UV treatment unacceptable in the case of flavourings (Art 3.2.k Regulation
(EU) 1334/2008)
In humans: the precursor of vitamin D is converted into vitamin D upon
sunlight (UV) exposure of the skin
A UV treated baker´s yeast („vitamin D yeast“) has been authorised in the EU
as a novel food (June 2014, COM Decision 2014/396/EU). The vitamin D
precursor ergosterol is produced by the yeast and requires UV exposure to get
converted to vitamin D2. That UV treatment is made part of the process.
UV treatment acceptable in this particular case as being compliant with
„natural“? *

Case by case assessment is the way forward
*author of this presentation has not evaluated the whole process of this vitamin D yeast.
The product as a whole may or may not qualify as „natural“.
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Processing aids naturally part of processes
Substances used during processing must meet legal definition of
`processing aid`
- unintentional presence in the food ingredient
- only unavoidable residues remain in ingredient
- residues do not have technical effect anymore
- residues of no health concern
Processing aids are not ingredients per legal definitions
Processing aids should meet the conditions in Codex Guideline
CAC/GL 75-2010 on processing aids
Enzymes are acceptable as processing aids
 very important for innovation
 e.g. changing a whole manufacturing process towards more
naturalness : chemical synthesis  fermentative/enzymatic
processing
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Proposed notion for processing aids use
Processing aids are commonly used in the manufacture of food
ingredients. They are per definition (Codex Stan 192-1995) not
ingredients, their presence is unintentional and only technically
unavoidable residues remain in a product which have no
technical effect anymore. As such, processing aids have no
impact on the assessment of the natural status of a food
ingredient by themselves other than being part of a process
applied. Proecssing aids and their use should be in compliance
with Codex Guideline CAC/GL 75-2010.
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Maximising relevance of ISO standard
• Standard intended to cover all food ingredient
• Food ingredients portfolio very diverse
• Competition and innovation occurrs between ingredients of
same kind/function
 ISO standard must allow for development of more
specific ‚natural‘ criteria for ingredients of same
kind/function w/o being in contradiction to ISO criteria
• example: NATCOL position on the term `natural colour`and
the categorisation of food colours http://www.natcol.org/
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ISO standard expected to complement NATCOL
`natural ` guidance
ISO likely encompasses ALL food ingredients and cannot be as
specific as the NATCOL `natural colour`guidance is
NATCOL guidance provides labelling recommendations which ISO
will not
NATCOL guidance is specifically reflective of the differences
within the food colour segment, ISO will not
NATCOL colour specific criteria unlikely in contradiction to less
specific ISO criteria
NATCOL guidance of immediate practical relevance for food
industry while ISO will remain more on „high level“
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EU regulatory scheme for foods / food ingredients imparting colour to foods
Art 3(2)(a)(ii) of
Regulation 1333/2008
Art 3(2)(a) of Regulation 1333/2008
Foods normally
consumed as a food in
itself
Coffee, tea,
Beetroot
Foods normally used
as characteristic
ingredients of foods
Coffee candies,
Saffron rice
Sepia spaghetti
Malt bread
Paprika chips
Foods, dried or
concentrated used with a
secondary colouring effect
Tomato paste
Cacao powder
Paprika powder
Annex I (1)
of Regulation 1333/20008
Foods to delineate
directly from food
colours
flavourings

Paprika flavouring


Food
colours
Selective/non
selective extraction
physical and/or
chemical extraction
Primary use is
colouration
Fruit juices and fruit juice
concentrates according to
Directive 2001/112/EC
Blackcurrant
juice concentrate
All these foods may impart colour to foods but their primary purpose of
use is a different one (i.e. characteristic ingredient, nutrition, aroma,…).
Their colouring effect is secondary.
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‘Colouring Foods’
(primary purpose of
use is colouration)
Specific focus
of NATCOL
guidance
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NATCOL colour classification principles
Three key criteria instead of two (ISO): (1) occurrence in nature,
(2) source material and (3) process
Introduction of definitions for differentiation between „artificial“
and „synthetic“
Terminology „colouring principle“ and „chromophor“ defined and
used to describe and classify a chemical modification
Differentiation into process categories and exemplified lists of
acceptable processes (open positive lists)
Classifies the legally permitted colours (EU) into categories along
the natural/artificial continuum and outlines labelling options per
colour category
 Of immediate and concrete practical relevance for finished
food industry while ISO only after certification?
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Summary and conclusion
• Innovation/competiton naturally occurrs between ingredients of same
function: colour against colour, sweetness against sweetness….
• Innovation is towards more natural ingredients in the natural/artifical
continuum (gradual)
• Too liberal standard  discourages innovation for food ingredient
manufacturers
• Too conservative standard  discourages innovation for the finished food
manufactures
• Required balance for a useful „natural“ concept can be spelled out in
terms of technical criteria
• ISO work to define „natural food ingredients“ worth to get support
• NATCOL natural colour guidance remains highly valuable and likely spells
out more concretely and practically relevant future ISO criteria which
remain
more „high level“
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