Fats and Oils

According to FDA this term means that the product is free of artificial ingredients or added colors and has only been minimally processed (minimal processing means that the product was processed in a way that has not fundamentally changed it). If a producer chooses to use this term, the label must include a statement explaining how the producer has defined use of the term. For example, the label must say “no artificial ingredients” or “minimally processed.” In short, “natural” indicates that nothing has been added to “a food that would not normally be expected to be in that food.”

Canola oil is the “fully refined, bleached, and deodorized edible oil obtained from certain varieties of [rapeseed plants].” Vegetable oil is generally defined as an oil extracted from plants, usually from seeds or nuts, but also from fruits and grains. Vegetable oils are required to list the specific vegetables from which the oil is produced (for example, “vegetable oil shortening (soybean and cottonseed oil)”). If there are multiple sources, they must be listed in descending order of prominence. More information is available in FDA regulations.

There is no federal definition for this term, but generally, cold-pressed oils are made by first grinding nuts, seeds, fruits, or vegetables (depending on the oil being made) into a paste. The paste is then pressed at a temperature below 120 ℉ (49 ℃).

COOL is required by US Customs and Border Protection for imported foods. COOL must not be false or misleading. To be considered a product of the US, an imported food must have undergone a “substantial transformation” in the United States. More information is available in Customs and Border Protection regulations.

This term does not have a specific legal definition, but expeller-pressed oils are extracted by exposing the food to extreme pressure. This also may or may not involve heat.

FDA has not defined the term “extra virgin” for coconut oil. The terms “virgin coconut oil” and “extra virgin coconut oil” are often used interchangeably and there is no substantial difference between the two. Both kinds of coconut oil are produced by pressing fresh coconut meat and separating the milk from the oil.

As of 2016, FDA has not approved the use of phrases like “good source of,” “rich in,” or “high in” for the Omega-3 acids DHA, APA, and ALA because there is no FDA-established nutrient level to which those claims refer. This likely means that claims like “good source of Omega-3s” are also prohibited. However, labels may make statements about the precise quantity of Omega-3s like “contains 1g of Omega-3” as long as that statement is true and not misleading. In 2019 FDA released enforcement guidance that indicates it will not object to labels claiming EPA and DHA Omega-3 consumption can decrease the risk of hypertension and coronary heart disease.

FDA allows the use of the term “healthy” (or related terms such as “healthful,” “healthily,” “healthiness,” etc.) as an implied nutrient content claim on food labels when it is useful for creating a diet consistent with dietary recommendations. The nutrient conditions necessary for a “healthy” diet include specific criteria for nutrients to limit in a diet, such as total fat, saturated fat, cholesterol, and sodium. The nutrient criteria to use this claim varies depending on the product and is different for raw fruits and vegetables than frozen or canned, enriched cereal products, and seafood or meat products. For more information on use of this term, see FDA’s Guidance for Industry: Use of the Term “Healthy” in the Labeling of Human Food Products.

Hydrogenation

Hydrogenation is the process of adding hydrogen to liquid oil. By adding hydrogen, the liquid oil becomes solid at room temperature. Manufacturers use hydrogenation for its preservative function, taste, and the texture it can impart in food. According to FDA regulations, “if the fat or oil is completely hydrogenated, the name shall include the term hydrogenated, or if partially hydrogenated, the name shall include the term partially hydrogenated.

Fully Hydrogenated Oils

These oils contain more added hydrogen than PHOs and create a more dense, solid fat. Fully Hydrogenated Oils have less trans fats than PHOs, and are not prohibited by the FDA. Fully Hydrogenated Oils must be listed simply as “hydrogenated oils” on ingredient lists.

Non-Hydrogenated Oils

Non-hydrogenated oils have not had any hydrogen added to their chemical structure. These oils are generally liquid at room temperature. Some non-hydrogenated oils may contain small amounts of trans fats depending on processing method and are not prohibited by the FDA.

Partially Hydrogenated Oils (PHOs)

PHOs are produced by adding hydrogen to an unsaturated fat, resulting in a shelf-stable, partially solid fat. In 2015, FDA declared that trans fats added to food through partially hydrogenated oils are no longer considered “Generally Recognized as Safe.” Beginning in 2018, food manufacturers were no longer permitted to add trans fats to food, but this compliance date was extended to January 1, 2020. After this date, food manufacturers cannot add partially hydrogenated oils to foods, because these oils are the primary source of trans fats. Trans fats must still appear on nutrition labels if they are present in the food.

This claim may be used if the food has a significantly reduced fat content compared to the regular form of the food. If the food regularly derives more than half of its calories from fat, the lite food must have 50 percent less fat than the regular form. If the food regularly derives less than half of its calories from fat, the lite version must have at least 33.3 percent fewer calories or 50 percent less fat than the regular version. In either case, the package must also declare “the identity of the reference food and the percent (or fraction) that the calories and the fat were reduced.” But in no case can a “low-fat” or “low-calorie” food be marketed as “lite” or “light.”

Where a regular serving size of a food is less than 40 calories and 3 grams of fat, the term “lite” or “light” may be used to note that the food has a reduced sodium content, if the sodium content is at least 50 percent less than the regular form of the food.

A food with a serving size greater than 30 grams (2 tablespoons) that has 3 grams or less of fat per serving is considered “low fat.” If the food’s serving size is less than 30 grams (2 tablespoons), or 50 grams if the food is dehydrated, and the food has less than 3 grams of fat per serving, the food is also “low fat.” If the food naturally meets these conditions or does not require special processing to meet these conditions, the label must “clearly refer to all foods of its type and not merely to the particular brand to which the label attaches (e.g., ‘frozen perch, a low fat food’).” More information is available in FDA regulations.

A product that is low in saturated fat contains less than 1 gram of saturated fat per serving and 15 percent or fewer of its calories come from saturated fats. If a food meets these conditions without the benefit of special processing, alteration, formulation, or reformulation to lower saturated fat content, it is labeled to clearly refer to all foods of its type and not merely to the particular brand to which the label attaches (e.g., “raspberries, a low saturated fat food”).

Olive oil

FDA currently does not have a standard of identity for olive oil. However, a 2019 petition to the agency called for the creation of a standard of identity. USDA, however, has set marketing standards for olive oil.

US Extra Virgin Olive Oil (EVOO)

This is virgin olive oil which has excellent flavor and odor, with minimal or zero defects, “fruitiness” measured greater than zero, and a free fatty acid content. For more specific details see the USDA Standards For Grades of Olive Oil, available here.

US Refined Olive Oil

This is from virgin olive oils manufactured through refining methods that do not alter the basic molecular structure of the oil. It is flavorless and odorless and meets the additional requirements in the USDA Standards For Grades of Olive Oil.

US Virgin Olive Oil

This is virgin olive oil “which has reasonably good flavor and odor (median defects between zero and 2.5 and median of fruitiness greater than zero) and a free fatty acid content.” Virgin olive oil cannot be graded above US Virgin Olive Oil. For more specific details see the USDA Standards For Grades of Olive Oil, available here.

FDA has not explicitly defined “pure” but based on guidance documents, FDA uses “pure” to mean a single-ingredient food with no other added ingredients like sugar. Consequently, “pure” canola oil is canola oil with nothing added.

Refined oils are extracted using heat, which can cause natural nutrients, aroma, and flavor to be lost. There is no federal definition for refined oil, but FDA does refer to refined oils in allergen guidance. “Highly” refined oils are not currently considered major food allergens and are explicitly exempt from the labeling requirements of the Food Allergen Labeling and Consumer Protection Act of 2004.

Saturation

All fat is made from hydrogen and carbon. Fats differ in consistency and nutrition depending on the structure of the hydrogen and carbon bonds.

Saturated Fats

Saturated fats have the most hydrogen. Saturated fats tend to be solid at room temperature because of the high-hydrogen content. Saturated fats occur naturally in animal products and meat.

Unsaturated Fats

Unsaturated fats are generally liquid at room temperature and come primarily from plants and fish. Unsaturated fats have fewer hydrogen atoms and include polyunsaturated fats and monounsaturated fats.

Trans Fat

Trans fat can occur as a by-product of hydrogenation (adding hydrogen to unsaturated fats) or naturally in some animal products like cheese and meat. Since 2003, manufacturers have had to include the amount of trans fat on nutrition labels. In 2015, FDA declared that trans fats added to food through partially hydrogenated oils are no longer considered “Generally Recognized as Safe.” Beginning in 2018, the FDA prohibited  adding trans fats to food through partially hydrogenated oils, but this compliance date was extended to January 1, 2020. After this date, food manufacturers cannot add partially hydrogenated oils to foods, because these oils are the primary source of trans fats. Trans fats must still appear on nutrition labels if they are present in the food.

There is no federal definition for unrefined oil, but this term refers to how oil is extracted. Unrefined oils are extracted using pressure rather than heat, which keeps most of the nutrients and flavor in the oil intact.

This term means that a product has been produced according to the standards in the Organic Foods Production Act (OFPA) and certified by the USDA’s National Organic Program. A label may only use the “USDA Organic” seal if the food is actually certified organic. However, a package may still note which ingredients, or percentage of ingredients, are USDA organic. Some producers, such as organic farmers who sell less than $5,000 in food per year may also market their products as organic without certification.

Organic products are grown and processed according to federal standards on soil quality, pest and weed control, and use of chemical fertilizers, among other areas. According to USDA, “[o]rganic producers rely on natural substances and physical, mechanical, or biologically based farming methods to the fullest extent possible.” Additionally, the use of genetically modified organisms is “prohibited in organic production or handling.”

The amount of organic ingredients in a food matters for labeling. A “100 percent organic” product may only have ingredients that are organic. A food that has at least 95 percent organic ingredients may have the term “organic” on its label if the organic ingredients are specifically noted somewhere on the package. If the product has at least 70 percent organic ingredients, the package may use the term “organic” to list the specific qualifying ingredients, but may not use the “USDA Organic” seal. Foods with organic ingredients, but less than 70 percent organic, may only use the term “organic” in the ingredient list or the percentage of organic ingredients. For more information on organic ingredient labeling, see the USDA Organic Labeling Standards website.

According to FDA, virgin olive oil is the oil from the first pressing of the olive fruits that yields oil suitable for human consumption.