Defining the term ‘natural’ in the context of food products - Natural Food Additives, Ingredients and Flavourings - page 6

The defi nition of food

Regulation (EC) No. 178/2002, Article 2
For the purposes of the Regulation 'food' (or foodstuff) means any substance
or product, whether processed, partially processed or unprocessed, intended
to be, or reasonably expected to be ingested by humans.

Further clarifi cation of this defi nition is provided in Recital 16 of the fl avourings
regulation (No. 1334/2008):

Materials of vegetable, animal or microbiological origin, for which it can
be suffi ciently demonstrated that they have hitherto been used for the
production of fl avourings, are considered to be food materials for this
purpose, even though some of these source materials, such as rose wood
and strawberry leaves, may not have been used for food as such. They do
not need to be evaluated.

So providing that there is suffi cient evidence and a history of the use of source
materials that are not consumed as food in the production of fl avourings, the
commercial fl avourings derived from them will not have to be evaluated. If,
however, there are concerns about the source materials EFSA can apply the
precautionary principle and have them evaluated.

1.2.3 Flavourings that cannot be natural in the EU
In the EU, thermal process fl avourings, smoke fl avourings, fl avour precursors and
other fl avourings cannot be natural; they are precluded by omission. There is
really no explanation or logical reason why this should be the case because
thermal process fl avours, for example, simulate cooking processes and would
fulfi l the criteria for natural if their source materials were natural and their
preparation complied with Annex II traditional food preparation processes.
The situation is further complicated by the new defi nition of 'fl avour precursor'
- defi ned in Regulation (EC) No. 1334/2008 under Article 3.3(g) (see below).
These fl avourings, when added to food, generate fl avour by reaction as the food is
being processed and like thermal process fl avourings, cannot be natural in the EU.

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Flavour precursor

Regulation (EC) No. 1334/2008, Article 3.2(g)
'Flavour precursor' shall mean a product, not necessarily having fl avouring
properties itself, intentionally added to food for the sole purpose of
producing fl avour by breaking down or reacting with other components
during food processing.

If we take, for example, a mixture of natural source materials such as the reducing
sugar glucose and the amino acid glycine with the intention of adding them to a
food product so that they react in situ to develop fl avour as the food product is
being processed, the mixture cannot be called natural. Although both components
are natural and they are mixed using a traditional food preparation process listed