Labeling Explainer: Naming Foods with Added Flavorings

Neal Fortin<$author.email> - February 23, 2024

Here is a quick overview of naming foods with added flavorings, from the faculty of the MSU Food & Dietary Supplement Labeling Workshop. March 5-6, 2024. Orlando, Florida.

Image of a strawberry milk carton. Text reads

Learn more at the Food & Dietary Supplement Labeling Workshop.

Orlando, March 5-6, 2024.

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Characterizing Flavor

The characterizing flavor(s) is the primary recognizable flavor(s), flavor in the statement of the identity, or any image on the label that implies a flavor. For example, if you show strawberries on the label, strawberry is considered a characterizing flavor. When a statement of identity includes a flavor term or graphic and the flavoring was added, the required flavor descriptions listed below in at least one-half the type size of the flavor name.

21 C.F.R. 101.22(i)

No Qualification

If no artificial flavor is added to simulate, resemble, or reinforce the characterizing flavor, and the expected food ingredient creates the flavor, or
If natural flavoring is used to reinforce the flavor of the food ingredient, but the food ingredient is sufficient to independently characterize the flavor,

Then, only the common name of the characterizing flavor is included in the name of the food.

“Vanilla Wafers” [All flavor from vanilla bean]
“Strawberry Shortcake” [Enough strawberries to independently characterize the flavor but additional natural strawberry is added to enhance flavor]

21 C.F.R. 101.22(i)(1)

"Flavored" Means:

None of the characterizing food ingredient is in the recipe (e.g., no strawberries in strawberry shortcake), but natural flavor from the food is added or
Natural flavor from the food is added, and the characterizing food ingredient is also added but is insufficient to independently characterize the flavor.

The characterizing flavor is preceded or followed by “flavored” in the name of the food. The term “natural” may preceded the term “flavoring.”

“Natural Strawberry Flavored Shortcake”
“Strawberry Flavored Shortcake”

(21 C.F.R. 101.22(i)(1)(i))

“Artificial Flavor” Means:

None of the natural flavor used in the food is derived from the product whose flavor is simulated (unless labeled with the source of the flavor), or
Artificial flavors are added to simulate, resemble, or reinforce the characterizing flavor from the food, with or without the characterizing flavor ingredient, or
Natural flavor from other than characterizing ingredient is used, and the characterizing ingredient is insufficient to flavor the food.
“Artificially Flavored Strawberry Shortcake”
Artificial Strawberry Flavored Shortcake”

21 C.F.R. 101.22(i)(1)(ii) and 101.22(i)(2)

"With Other Natural Flavor" Means:

Contains both the characterizing flavor from the named food along with natural flavor which simulate, resemble, or reinforce the characterizing flavor.
- “Strawberry shortcake with other natural flavor”

21 C.F.R. 101.22(i)(1)(iii)

This information is for educational discussion purposes only. This is an overview. Consult the reference for additional information.

Learn more at the Food & Dietary Supplement Labeling Workshop in Orlando, March 5-6, 2024.

Disclaimer.

Institute for Food Laws and Regulations