Ireland gives guidance on 'natural' marketing

by Jeff Gelski
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DUBLIN — While no federal definition of “natural” exists in the United States, the Food Safety Authority of Ireland on May 14 provided guidance on “natural” as a marketing term as well as three other marketing terms in “artisan/ artisanal,” “farmhouse” and “traditional.”

The guidance will apply to the labels of all food placed on the Irish market and/or presented and advertised after December 2016. Food businesses outside of Ireland that produce food to be placed on the Irish market should use the guidelines or equivalent guidelines recognized by their national competent authority, according to the FSAI.

The guidelines said that for a single ingredient food, such as a bag of carrots, to be marketed as natural, it should be formed by nature and not significantly interfered with by man.

“‘Significantly interfered with by man’ does not include minimal processing like: chopping, slicing, grinding, peeling, juicing, blanching, pasteurizing, freezing, drying, etc. as these do not significantly change the nature of the food,” the FSAI said. “It does include more complex forms of processing like: concentration, cooking processes more severe than pasteurization (70ºC for 2 minutes or equivalent), curing, brining, refining, chemical extraction, genetic modification, cloning, etc. Fermentation is also considered a ‘natural’ process, but subsequent processes may disqualify the final product from the description ‘natural.’”

The guidelines said that for a compound food to be marketed as natural, it should meet two criteria. First, the ingredients in the food should be formed by nature and not significantly interfered with by man. Second, the ingredients and the final food should be additive-free, or contain flavorings that are natural as defined in European law, or contain other food additives that are obtained from natural sources like plants by appropriate physical processing, including distillation and other solvent extraction, or traditional preparation processes.

Guidance for artisan/artisanal marketing involves four criteria. First, the artisan/artisanal food must be made in limited quantities by skilled craftspeople. The FSAI defined limited quantities as total production of less than 1,000 kilograms (a little more than 2,200 lbs.) or 1,000 kiloliters (about 264,000 gallons) of food per week on average over a year.

Second, the processing method should not be fully mechanized and should follow a traditional method. Third, the food should be made in a micro-enterprise at a single location. The FSAI defined micro-enterprise as one that employs fewer than 10 people and whose annual turnover and/or balance sheet total does not exceed €2 million ($2.23 million). Fourth, the characteristic ingredient or ingredients used in the food should be grown or produced locally, which means within 100 kilometers, or about 62 miles, of the manufacturing/food service establishment.

Guidance for “farmhouse” involves three criteria. First, the food should be made in a single location on a farm. Second, the food should be made in a micro-enterprise. Third, the characteristic ingredient or ingredients used in the food should be grown or produced locally.

Guidance for “traditional” involves two criteria. First, the food should be made based on a recipe that has existed without significant modification for at least 30 years. Second, the method of preparation should have existed for more than 30 years, although automation and mechanization of the methods are acceptable, and the method of preparation should not deviate substantially from the traditional food processing method associated with a certain type of food.

“Marketing terms are designed to resonate with consumers and are an essential part of business development in the food industry,” said Wayne Anderson, Ph.D., director of food science and standards for the Food Safety Authority of Ireland, based in Dublin. “However, they have the potential to mislead when used incorrectly. The guidance published (May 14) addresses this concern and is the culmination of extensive industry engagement on this issue.”

The guidance follows a public consultation carried out by a working group that included the FSAI, the FSAI’s Artisan Forum, Food and Drink Industry Ireland, and the Consumers’ Association of Ireland. The guidance is available at www.fsai.ie.
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