Grains

FDA does not have a formal definition for what this label means, but it has acknowledged a “longstanding policy” concerning the use of the word “natural” in food labeling. According to this guidance, natural food is free of artificial or synthetic ingredients which are not normally expected to be in that food. This includes all color additives, regardless of whether they are artificial.  If a producer chooses to use this term, the label must include a statement explaining how the producer has defined the term. For example, the label must say “no artificial ingredients” or “minimally processed.” Minimal processing means that the product was not processed in a way that fundamentally changed the product. In short, nothing has been added to “a food that would not normally be expected to be in that food.”

FDA has not established a definition of this term. The Whole Grains Council, a nongovernmental advocacy group, loosely defines ancient grains as “those that are largely unchanged over the last several hundred years.” This includes grains like quinoa, farro, millet, and spelt.

FDA considers this an authorized health claim for grain products that contain fiber. Health claims are label claims about health-related conditions. FDA authorizes health claims when they are supported by significant scientific agreement, meaning the claim can be used without further qualifying language. If the health claim is not supported by significant scientific agreement, the producer must include qualifying language on the label to explain the state of the science. Health claims require FDA notification at least 120 days before the food is introduced into interstate commerce.

Low Fat

This is an example of a voluntary nutrient content claim, which characterizes the level of an individual nutrient in the food product. A low-fat product has been specifically processed or formulated to have less than 3 grams of fat per serving. If the food naturally has less than 3 grams of fat per serving, the label should note that all foods of that type are low in fat, for example, “brown rice, a low-fat food.” See FDA regulations for more information.

No Trans Fats

Manufacturers are permitted to make this claim when a product has less than 0.5 grams trans fats per serving, even if the full product has more than 0.5 grams of trans fats total. For example, if a serving size of crackers contains less than 0.5 grams trans fats, a family sized box of those crackers may be labeled “no trans fats” even though the total amount of trans fats in the box amounts to more than 0.5 grams. See FDA regulations for more information.

This claim means the food does not contain more than 20 parts per million of gluten (below 20 mg of gluten per kg of food). FDA explains, “[t]his level is the lowest that can be reliably detected in foods using scientifically validated analytical methods. Other countries and international bodies use these same criteria, as most people with celiac disease can tolerate foods with very small amounts of gluten.” This is a voluntary label claim, meaning that the manufacturer has no obligation to label whether the food is gluten free, but may choose to do so for marketing benefits. Because it is a voluntary claim, the food may be made of ingredients that inherently do not contain gluten or ingredients that have been specifically processed to remove gluten. So, both specialty foods like gluten-free breads and foods that naturally do not contain gluten like fruits and vegetables may all be labeled “gluten free” as long as the food has less than 20 parts per million of gluten. For more information see this FDA source.

FDA does not define this term. Heritage plant varieties usually refer to plant breeds that have been cultivated over several generations using traditional methods to enhance specific plant traits. For example, producers may use this term to refer to wheat varieties that existed before modern high-yield grains developed through hybridization. See this Smithsonian piece for more information.

FDA does not define whole grain, but nonbinding FDA guidance defines the term as “[c]ereal grains that consist of the intact, ground, cracked or flaked caryopsis, whose principal anatomical components—the starchy endosperm, germ and bran—are present in the same relative proportions as they exist in the intact caryopsis.” General consumer and industry perception of this term indicates that a whole grain includes 100 percent of the original kernel—all of the bran, germ, and endosperm. Beyond this, the claim must not be false or misleading, and may not “imply a particular level of the ingredient, i.e., ‘high’ or ‘excellent source’.” FDA has created a list of FAQs as to when manufacturers can use the term “whole grain.”

“GMO” stands for “genetically modified organism.” While there are no USDA or FDA regulations that specifically define this claim, both agencies have working definitions of “genetic modification.” USDA defines “genetic modification” as “[t]he production of heritable improvements in plants or animals for specific uses, via either genetic engineering or other more traditional methods.” FDA’s longstanding position on the term “GMO” is that even traditional plant breeding methods, like selective breeding, fall under “genetic modification.” FDA guidance recommends that producers do not use the term “non-GMO” and instead use terms like “not produced using modern genetic engineering” because consumers may not realize that traditional plant breeding methods can be considered genetic modification, and that the majority of foods “do not contain whole organisms.” However, FDA has stated that it does not intend to take action against producers that use these label claims “as long as the food is, in fact, not derived from a genetically engineered plant and the food’s labeling is not otherwise false or misleading.” FDA considers it misleading for any label to imply that food without genetically engineered ingredients is in any way superior to those products without a similar label. FDA considers food that is certified 100 percent organic to satisfy the “non-GMO” standard.

Third-party certifiers (e.g., the Non-GMO Project) have a set of standards for certifying products. Additionally, beginning in 2022, certain foods will be required to disclose whether they contain “bioengineered food” under the National Bioengineered Food Disclosure Standard. See our issue brief “Consumer’s Guide to Bioengineered Food Disclosures” for more information.

The use of this claim is not specifically regulated by FDA, since it is not referencing an element of the food that provides nutrition to the body such as protein, carbohydrates, fats, vitamins, or minerals. FDA defines chemical preservatives as “chemicals added to food that tend to prevent its deterioration, excluding common salt, sugar, vinegar, spices, oils, substances added to food through a wood smoking process, and chemical pesticides.” And, because a label cannot be false or misleading, this likely means that the food does not contain a chemical preservative as defined in FDA regulations.

Neither USDA nor FDA has defined this claim. This claim does not define a strict category and can be used at the manufacturer’s discretion as long as it is not false or misleading. This term is commonly used as a buzzword meant to note that a product is high in beneficial vitamins and nutrients.

Traditional is not defined by FDA but is often used as a synonym for ancient grains. Traditional may also refer to the way grains are processed, like through a traditional stone grain mill. But without a clear definition, the only limitation on using this term is that it cannot be false or misleading.

This term means that a product has been produced according to the standards in the Organic Foods Production Act (OFPA) and certified by USDA’s National Organic Program. A label may only use the “USDA Organic” seal if the food is actually certified organic.

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.”

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. For more information on organic ingredient labeling, see the USDA Organic Labeling Standards website.