Why can't the phrase "All Natural" apply to all dietary supplements?
Americans are developing an insatiable appetite for natural products. An aging population, obesity crisis, and increasing concern over the sustainability of the food system have resulted in an evolving marketplace that sets a strong premium on products that come from the hands of the farmer, not the pharmacist.
According to a recent report from the Consumer Reports National Research Center, over 60% of adult shoppers purchase foods labeled as “natural” regularly.1 For a product marketer in the supplement industry, this trend creates a natural desire (no pun intended) to make the “All Natural” claim where applicable. Being able to advertise that your products come from nature is good business.
However, for many products using the phrase “All Natural” carries significant legal risk, even if its marketing appeal is hard to ignore. For this reason using caution with the claim is necessary, even if it’s really tempting to want to slap it on there and appeal to the green-washed masses.
'All Natural' Dietary Supplements Should Be From Nature
The official legal meaning of the phrase “All Natural” is imprecise, but in the past the FDA has defined the term like so:
The term "natural" applies broadly to foods that are minimally processed and free of synthetic preservatives; artificial sweeteners, colors, flavors and other artificial additives; growth hormones, antibiotics, hydrogenated oils, stabilizers and emulsifiers.2
The basic idea being that if an ingredient has artificial origins, you can’t use the term. When it comes to dietary supplements this means processing additives like flavorings, excipients (magnesium stearate), emulsifiers (gums and lecithin), and bulking agents (silica and citric acid) make many dietary supplements unbecoming of the term.
What about vitamins and minerals?
Most vitamins and minerals are made in a lab. Even ones that are advertised as coming from food are usually synthetic isolates that are blended with some sort of yeast or extract in order to make the whole food claim. Mother nature generally doesn’t provide nutrients in dense enough form to produce extracts suitable for finished products.
Most of the time, including these ingredients means that a significant portion of your ingredient stack is from synthetic origins, making the “All Natural” claim dubious.
The Pressure’s Heating Up
Despite its vague definition, there’s an increasing amount of legal scrutiny around using the phrase “All Natural” in marketing vernacular. Surveys have found that a majority of people conflate being “natural” with being “organic”,1 which has created the potential for abuse among marketers looking to capitalize on confusion between the two.
An organic product is a natural product, but the reverse is not true. While the phrase “All Natural” makes specific reference to a product’s origins, it says nothing about how a product is produced. The organic standard is a set of documents that has precise specifications for how all products bearing its label are made. Its requirements go above and beyond the generalities surrounding the natural term and, for this reason, consumers and regulators are making it a priority to draw clear lines between the two.
The more important and desirable a marketing claim becomes, the more pressure builds to make sure its use isn’t abused. The issue of properly defining the “All Natural” phrase has become important enough that the FDA is now accepting consumer input on how they wish the term to be regulated in anticipation of upcoming legislative changes surrounding how the claim can be used.
Being able to make robust label claims is an obvious goal in the product development process and entrepreneurs would be foolish not to strategically plan to use them to differentiate their brand. However, marketing zeal needs to be counteracted with legal prudence in an industry that’s facing increasing pressure to be more transparent with how it markets to its customers.
For this reason we think it’s a good idea to use the “All Natural” phrase with caution and only when it can be absolutely verified.
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