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Sarah's avatar

Hi Brittany, thanks for sharing this—really appreciate the discussion! Coming from the nutrition and regulatory compliance side, flavors can definitely get tricky. One nuance worth noting in your vanilla protein bar/blueberry extract section: when vanilla is the characterizing flavor, the standard of identity in 21 CFR 169 takes precedence over the general flavor labeling rules in 21 CFR 101.22. So for a product called “Vanilla Protein Bar,” we wouldn’t expect vanilla extract to be labeled as “natural flavor.”

Also, the section you highlighted about “if none of the natural flavor used in food is taken from the food that the flavor is simulating…” applies to natural TYPE flavors—those that mimic a flavor but aren’t derived from it. If you have a blueberry protein bar that has a natural blueberry type flavor, that flavor is from natural sources but may be derived from flavors like raspberry, orange and strawberry to create a flavor profile that tastes like blueberry. In that circumstance, if the blueberry protein bar contains no other source of blueberries, it would be called "Artificially Flavored" on the front of pack. In your example, blueberry extract wouldn’t be simulating vanilla, so if the bar doesn’t show blueberries on the label or make any indication of blueberries, blueberry could be listed as “natural flavor.” Flavor labeling usually centers on the characterizing flavor, which here is vanilla.

There are other quirks too—like when a product can say “artificially flavored” on the front but list “natural flavor” in the ingredient declaration. Definitely a complex area!

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Dinah's avatar

Do you know if Gluten is considered a priority allergen that must be listed in Natural flavours in Canada and the US?

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