“Our industry is committed to providing consumers with labeling information in the clearest possible terms in order for them to make informed product purchases,” says Karin Moore, GMA’s senior vice president and general counsel. Moore says a clear definition will alleviate confusion for both consumers and food and beverage manufacturers.

FDA announced last year it was seeking comment on the use of the term “natural.” GMA had filed a citizen petition with FDA in 2014 asking the agency to set a definition for the term, one of three petitions on the subject filed with the agency. Federal courts have also requested clarification from FDA on the proper use of the term “natural” in food labeling due to ongoing litigation.

“The criteria used to determine if a food qualifies for a ‘natural’ claim should focus primarily on whether the product’s ingredients are synthetic/artificial or natural and on the degree of processing the ingredients have undergone,” Moore says. GMA added its definition should be distinctly different from the term “organic.”

In its submission to FDA, GMA provides specific comments regarding how the term “natural” should be defined, in response to FDA’s questions and, as an alternative approach, a tiered system for “natural” claims that would distinguish between an “all natural” or “100% natural” claim and a “natural” claim.

The GMA comments also said that farming and agricultural methods used in the production of a crop, including pesticide or herbicide use, the use of biotech seeds, or animal husbandry (e.g., “free range,” “grass fed,” “fair trade”, etc) should not have a bearing on the “natural” status of a food or ingredient.