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August 26, 2020 Lottie Bingham By Lottie Bingham My Articles

What is ‘Natural Food’?

Rising demand for ‘natural’ foods has seen the term often used as a marketing tool in advertisements and packaging. But what exactly does ‘natural’ mean, and how are the claims legally regulated?

Existing Regulations 

There are currently just two categories of consumables regulated by EU law in terms of their eligibility to be deemed ‘natural’. These are water, and flavourings–both of which can only be classed as ‘natural’ if they adhere to specific guidelines:1,2 

Natural Water

Water can only be classed as ‘natural mineral water’ if the source, mineral composition and microbiological state is the same as it was at source, with no additional treatment. Carbon dioxide can still be added to make ‘natural mineral water’ sparkling, without compromising it’s ‘natural’ standard.1,3,4,5

Natural Flavourings

Flavourings must have been extracted, using only certain condoned techniques, from either a vegetable, animal or microorganism that is present in nature. Any flavouring that does not meet all criteria not only loses its status as ‘natural’, but must also be identified in the ingredients as ‘artificial’.2

Lack of Regulation?

For other food and drink products, however, there are no clear definitions identifying what can and cannot, under EU law, be described or sold as ‘natural food’. There exists a catch-all regulation stating that, for all food and beverage products, no component of the labelling, advertising, or presentation, can be ‘misleading’. However, when it comes to definitively fluid terms such as ‘natural food’, how do you determine whether the term has indeed misled the consumer?6,7

What Does “Natural Food” Legally Mean?

In response to this ambiguity, certain EU states have outlined what they consider to be the meaning of the term ‘natural’, regulating how and when retailers can use the phrase. In the UK, the Food Standards Authority (FSA) stipulates that ‘natural’ dairy products must be manufactured only from mammals’ milk, using only the necessary fermentation cultures, and are ‘plain’, i.e. free from additives such as preservatives, flavourings, or colours. Take ‘natural yogurt’ or ‘natural cottage cheese’, for example, which derive their flavour solely from the ingredients essential for the product’s manufacturing, without adjustment by any other means.8,9

When “Natural” Can’t Be Used

Beyond dairy, the FSA have further stipulated when the phrase ‘natural’ can and cannot be used across all food and drink products sold within the UK. According to these restrictions, the term ‘natural’, without further qualification, can only be used to describe foods that have been produced solely by nature, as opposed to by man, including negating any human interference beyond that which is necessary to render the food suitable for human consumption.10

As a result only raw, unprocessed, single items can be described simply as ‘natural’ in the UK. However, other products made from natural ingredients that have been subject to some level of modification or processing can still use the word natural, so long as further explanation is provided. For example, a compound food – food made of more than one ingredient – could be described as ‘made from natural ingredients’, whilst a juice that has at some stage been frozen for preservation could be labelled as ‘frozen natural orange juice’.10

Interestingly, this level of regulation does not apply to those foods or companies for whom the word forms part of their name. Whilst the FSA stipulates that if ‘natural’ is present in a brand name, it cannot be used in such a way that implies the foods themselves are “natural” if they do not actually meet the legal standards for ‘natural’. This does not, however, stop the term being present on the brand’s packaging (even if the food is anything but ‘natural’) and would likely still impact the consumer’s perception of how ‘natural’ the food is.10

The Issue With Defining ‘Natural’ In The EU

If the UK’s FSA regulates the term ‘natural’ on food products, why is there a lack of clarity when it comes to providing an overarching EU regulation? Petr Mensik, Manager of EU Affairs at The European Consulting Company, believes it comes down to the numerous points within the chain of production which can have human involvement, with each process making the end product that one step further removed from that which was originally obtained from the earth. Even if we were able to agree that a certain level of human interference is acceptable, drawing a distinct line between which (or how many) of those processes would be considered too many, he says, is impossible.11

This difficulty is supported by a 2017 study that asked consumers from 32 (mostly) European countries to identify what facets of a food product are important in determining whether it could be considered natural, and where the line could be drawn for each of these factors.12,13

3 key factors were identified:

  1. Raw materials
  2. Further additives or ingredients
  3. The level of human manipulation/processing

Unsurprisingly, the last factor was the greatest point of contention across all surveyed individuals. Some stated that a ‘natural’ food must only have minimal processing, so that the ingredients resemble their raw form as closely as possible. Others were more happy to compromise for the sake of convenience. The major stumbling block identified by the study, however, was the finding that there were distinct difference between populations: different countries interpret the term ‘natural’ to have substantially different meanings when it comes to food, making a single definition near-impossible.12

‘Natural Food’: Open To Interpretation

While this might explain why the EU has thus far been reluctant to provide a definition for ‘natural’, and instead relies on individual states for regulation, it also reveals that the word ‘natural’ holds value to consumers. The researchers concluded that identifying a common definition for ‘natural’ would actually be beneficial in providing clarity for consumers. However, rather than looking for just one single definition, the ‘naturalness’ of food should not be a binary concept with one single meaning, but rather a spectrum. 

Following this thought process, different phrases such as ‘100% natural’, or ‘contains natural ingredients’ could be used to identify the degree of ‘naturalness’ of any given product. This could enable producers to utilise the phrase even when their products are not single, raw, unprocessed items, but avoids the consumer being misled. 

However, despite these findings the EU has made no clear plans for developing such a definition or scale - so for now, the meaning of ‘natural’ remains somewhat open to interpretation.12

Does the term ‘natural food’ encourage you to buy a product, and would you prefer for there to be greater clarity and regulation as to what it actually means when used to describe food? Let us know in the comments below!

August 26, 2020 Lottie Bingham By Lottie Bingham My Articles

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  1. Official Journal of the European Union (2009). “on the exploitation and marketing of natural mineral waters”. Accessed 9 July 2020.
  2. Official Journal of the European Union (2008). “on flavourings and certain food ingredients with flavouring properties for use in and on food and amending Council Regulation (EEC) No 1601/91, Regulations (EC) No 2232/96 and (EC) No 110.2009 and Directive 2
  3. British Soft Drinks Association (2008). “Labelling of Bottled Water”. Accessed 9 July 2020.
  4. Food Standards Agency (2017). “Natural Mineral Water, Spring Water and Bottled Drinking Water Regulations in Wales and Northern Ireland”. Accessed 9 July 2020
  5. European Federation of Bottled Waters (2020). “Natural Mineral Water”. Accessed 17th July 2020
  6. European Parliament and Council (2011). “General food information requirements and responsibilities of food business operators”. Accessed 10 July 2020.
  7. European Commission (2011). “Voluntary food information”. Accessed 10 July 2020
  8. Food Standards Agency (2002). “Criteria for the use of the terms fresh, pure, natural etc. in labelling”. Accessed 10 July 2020
  9. European Council (2011). “Additives”. Accessed 12 July 2020
  10. Vickery; Temple (2017). “Use of Term “Natural” When Advertising Food/Drinks Products”. Accessed 12 July 2020
  11. Mensik (2017). “Defining the term ‘natural’ in food and beverage”. Accessed 10 July 2020
  12. Roman; Sanchez-Siles; Siegrist (2017). “The importance of food naturalness for consumers: Result of a systematic review”. Accessed 12 July 2020.