When is a Product Legally “Natural”?

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Jeffrey Johnson is a legal writer with a focus on personal injury. He has worked on personal injury and sovereign immunity litigation in addition to experience in family, estate, and criminal law. He earned a J.D. from the University of Baltimore and has worked in legal offices and non-profits in Maryland, Texas, and North Carolina. He has also earned an MFA in screenwriting from Chapman Univer...

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UPDATED: Jul 16, 2021

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ProduceProducts, from food to cleaning supplies, are increasingly labeled “natural.” Such “natural” products often command premium prices at stores like Whole Foods.

However, as the New York Times notes, “there is no legal or regulatory definition of what ‘natural’ is.”


To be labeled “organic” in the US, food and other agricultural products (including cotton) must be produced according to US Department of Agriculture (USDA) organic regulations that define standards for production.

The Organic Foods Production Act of 1990 

requires the Secretary of Agriculture to establish a National List of Allowed and Prohibited Substances which identifies synthetic substances that may be used, and the nonsynthetic substances that cannot be used, in organic production and handling operations.

As Reader’s Digest reports,

Organic foods undergo intense USDA regulations: No synthetic fertilizers, synthetic growth and breeding hormones, antibiotics, and GMOs; any pesticides used must be natural. It takes three years, and thousands of dollars in fees, for farms to go organic. Once certified, farmers get regular inspections, keep detailed logs and must stay prepared for surprise visits to test their soil and water“Natural” foods don’t have such rigorous scrutiny.

Consumer Confusion

Consumers tend to confuse the meaning of the words “natural” and “organic.”

As the Times states,

A survey of consumers in 2015 by Consumer Reports magazine showed that at least 60 percent of respondents believed “natural” on packaged and processed foods meant they contained no artificial colors or ingredients and no genetically modified materials.

That’s not actually the case.

The Food Bar

Companies are facing off with lawyers over “natural” labeling.

As the Times notes,

On one side are companies eager to cash in on consumers’ willingness to pay higher prices for natural products by slapping “all natural” labels on them. At times, the claims have stretched the limits of credulity — like “All Natural” 7Up, Pop-Tarts “Baked With Real Fruit” and Crystal Light “Natural” lemonade.

(Sugar, after all, is “natural.”)

Lawyers known as the “Food Bar” have filed more than 300 lawsuits seeking class-action status for plaintiffs in cases challenging alleged misrepresentation of foods labeled “natural.”

As the Times reports,

Among the brands that have faced legal challenges are several that have long promoted their use of natural ingredients: Tom’s of Maine antiperspirants and toothpastes, the Honest Company’s laundry detergent and dish soap, Annie’s Homegrown salad dressings, Breyers and Ben & Jerry’s ice cream, Aveeno face moisturizers and Seventh Generation dish soap.

Proponents of such suits say that they have protected consumers by forcing manufacturers to change their labels to make them more accurate.


However, some of the lawsuits seem to be both over-reaching and underestimating the intelligence of consumers. As the Times reports,

A federal judge tossed a case a few years back, for instance, after concluding that reasonable consumers would understand that the “crunchberries” in Cap’n Crunch cereal were not real fruit. But another judge in California last year refused to dismiss a case against Krispy Kreme, which claimed that consumers were denied the health benefits found in raspberries because the company’s “raspberry-filled” doughnuts did not include real fruit.


In 2015, the US Food and Drug Administration (FDA) sought comments from the public about whether the use of the term “natural” on food labeling should be regulated by the federal government.

However, the FDA has not yet engaged in rulemaking to establish a formal definition of the term.

According to its website,

The FDA has considered the term “natural” to mean that nothing artificial or synthetic  (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food.  However, this policy was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation. The FDA also did not consider whether the term “natural” should describe any nutritional or other health benefit.

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