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Writer's pictureBurdock Group Consultants

“Clean” Labels Must Also Mean Safe Foods

Updated: Mar 4

woman reading food ingredients label at grocery store

There has recently been an increased interest in cooking, as evidenced by the increase in the number of televised cooking shows, internet articles on cooking shortcuts and books describing the unique personal connections people have with the art of cooking. The interest in cooking has also increased the consumer’s desire to understand more about the ingredients that go into made-from-scratch food, or processed food. At the same time, consumers in this complex technological era seem to be searching for simplicity in the food products they consume. To address consumer concerns and requests for food products that contain easy-to-understand ingredients, food manufacturing companies have worked to produce a “clean” label, which at its core, is the concept that the ingredients added to food are recognizable or, at the least, with few to no ingredients that are labeled as preservatives, additives, artificial or have multi-syllabic “chemical”-sounding names.

All areas of the food industry are working to modify processed food products to make the ingredients that form the product more natural and “healthy,” by either utilizing alternative, naturally derived ingredients, or by finding new processing steps that remove the need for typical ingredients necessary in modern processing. For example, in May, the Kraft Heinz Co. reformulated the Oscar Mayer brand of hot dogs such that the entire line has no added preservative nitrates or nitrites, no byproducts in the meat and does not utilize artificial colors.1 This follows the removal of artificial colors and other artificial ingredients from their brand of mac-and-cheese product in 2016.2 The artificial colors that were previously used in Kraft Macaroni & Cheese were replaced with paprika, turmeric and annatto.

Clean label products are also associated with those products labeled as “GMO-free, “gluten-free,” and meats free of antibiotics or growth hormones. The International Food Information Council Foundation’s 2017 Food & Health Survey, an online survey of 1,002 Americans aged 18-80, asked how they defined a healthy food, to which 15 percent of the respondents said foods free from artificial ingredients, preservatives or additives was their No. 1 criteria for defining healthy food.3 Contrary to the “clean label” term, “gluten-free” and “GMO-free” have been defined to some extent by the U.S. Food and Drug Administration (FDA). Foods claiming to be “gluten-free” must contain less than 20 parts per million gluten, and foods inherently gluten-free may also utilize the term as well as foods that contain gluten-containing grains that have been processed to remove gluten.4 FDA has provided guidance on the labeling to signify the absence of plant- or animal-derived food ingredients that were produced using modern bioengineering, genetic engineering or modern biotechnology.5 “Clean label” has not been defined by FDA, which has caused some confusion in the food industry, as different companies can market their products as “clean label,” with no clear standard by which to assess the validity of the statement.

Companies striving for a “clean” label are searching for natural sources of ingredients that can replace their synthetic or “chemical-sounding” counterparts, even if the safety to support the intended use (and use level) for the product from a natural source is not as robust. For example, there has been a major increase in the use of naturally derived colors in a variety of foods, from cereals to cake mixes to beverages. Many of these naturally sourced colors are derived from currently consumed plants, as FDA regulations have provided the ability to utilize juices from fruits and vegetables as “exempt” color additives in foods without additional premarket review and FDA approval (while exempt color additives must comply with the identity and purity specifications and use limitations described in the regulations, there are essentially no specifications and limitations other than good manufacturing practices for fruit and vegetable juices as colors).6 Synthetic colors must undergo extensive preclinical toxicity testing and FDA premarket review prior to approval. FDA regulations do limit sources to the juice from certain fruit and vegetables — and, under certain conditions, as the fruit or vegetable from which the juice is made must have been safely consumed as food — but there are no stated constraints on changes in processing or specifications. Unfortunately, often the color constituents of the concentrated juice, typically anthocyanins or polyphenols, are sensitive to heat and acid changes during food processing, or light exposure during storage, and so the color degrades during processing or shelf storage.

To compensate for potential color degradation, many companies process the juice concentrate to help retain the vibrant colors found in the fresh juice concentrate, and the processing may alter the composition, or may concentrate components that could pose a health risk to sensitive populations. For example, the curcumin found in turmeric can inhibit SULT1A enzymes that metabolize the catecholamines dopamine, norepinephrine and epinephrine. Increased catecholamine levels in the blood can induce heart palpitations, headaches and high blood pressure, and can alter bodily responses to medicines taken to address these conditions.7

Food and color manufacturers need to fully characterize the ingredients they are producing to ensure that the end product is safe for the intended use. While the consumer continues to push for clarity and simplicity in the food they consume, the food manufacturer must also evaluate every ingredient utilized in the processed food for assurance that the ingredient is safe when used as intended. “Clean label” ingredients help the consumer understand the composition of a food product and enhance the healthy perception of foods, but those “clean label” ingredients must first be evaluated for safe use at the levels consumed in the daily diet.

References:

  1. http://www.foodbusinessnews.net/articles/news_home/Business_News/2017/06/Cleaning_up_processed_meat_app.aspx?ID={0526F863-E338-4C5B-9A5E-A03DE692A7C6}&cck=1; Cleaning up processed meat applications; site last visited June 29, 2017.

  2. http://money.cnn.com/2015/04/20/news/companies/kraft-macaroni-cheese-fake-color/index.html; site last visited June 29, 2017.

  3. International Food Information Council Foundation. 2017 Food & Health Survey; foodinsight.org/FHS; site last visited June 28, 2017.

  4. https://www.fda.gov/Food/NewsEvents/ConstituentUpdates/ucm407867.htm; Foods labeled gluten-free must now meet FDA’s definition; site last visited June 29, 2017.

  5. https://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/labelingnutrition/ucm059098.htm; Guidance for industry: voluntary labeling indicating whether foods have or have not been derived from genetically engineered plants; site last visited June 29, 2017.

  6. 21 CFR 73.250 and 21 CFR 73.260.

  7. Eagle, K (2012). Toxicological effects of red wine, orange juice, and other dietary SULT1A inhibitors via excess catecholamines. Food and Chemical Toxicology 50: 2243-2249.

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