Defining the term ‘natural’ in the context of food products - Natural Food Additives, Ingredients and Flavourings - page 5

The FSA in the UK also accepts that foods that are subjected to traditional
cooking processes using heat such as baking, roasting and blanching retain
their natural status. Also accepted by the FSA as traditional processes are
smoking, fermentation, dehydration, sieving and washing but curiously freezing,
concentration, pasteurisation and sterilisation are rejected on the grounds that
they do not accord with current consumer expectations of 'natural' foods. This is
very unhelpful and confusing because pasteurisation is heating and traditional
methods of dehydration include concentration processes, and it is quite certain
that a consumer cooking a joint of meat that had been stored by deep freezing
would still regard it as being natural.
Fortunately, Annex II of Regulation (EC) No. 1334/2008 (Table 1.1), which
takes precedence over national regulations, includes freezing and evaporation -
the latter covering both concentration and dehydration.

1.2.2 Flavouring preparations
The remaining group of fl avourings that qualify for natural status are fl avouring
preparations and their defi nition is described under Article 3.2(d) of Regulation
(EC) No. 1334/2008. The defi nition is in two parts: fl avouring preparations
produced from food and fl avouring preparations produced from material other
than food, and both categories are natural:

Flavouring preparations

Regulation (EC) No. 1334/2008, Article 3.2(d)
'Flavouring preparation' shall mean a product, other than a fl avouring
substance, obtained from;

(i) food by appropriate physical, enzymatic or microbiological processes
either in the raw state of the material or after processing for human
consumption by one or more of the traditional food preparation
processes listed in Annex II;
and/or
(ii) material of vegetable, animal or microbiological origin, other than
food, by appropriate physical, enzymatic or microbiological processes,
the material being taken as such or prepared by one of the traditional
food preparation processes listed in Annex II.

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However, although fl avouring preparations manufactured from materials 'other
than food' are natural under Article 9(b) of Regulation (EC) No. 1334/2008, they
will require evaluation and approval by the European Food Safety Authority
(EFSA) otherwise they cannot be sold in the EU. Materials other than food may
be fi bre, leaves, stalks, hulls, shells, etc. Because of the costs associated with
toxicological testing required for authorisation, the defi nition of food is important
if companies are to avoid this expense. Food is defi ned in a separate Regulation
(No. 178/2002; EC 2002):