What Counts as a Natural Flavour, and What Doesn't

“Natural” is a defined term for a flavouring in the European Union, the United States and Singapore, and is absent from the Australia New Zealand Food Standards Code. In the European Union, Article 16(2) of Regulation (EC) No 1334/2008 provides that “The term ‘natural’ for the description of a flavouring may only be used if the flavouring component comprises only flavouring preparations and/or natural flavouring substances.” In the United States 21 CFR 101.22(a)(3) defines “natural flavor” for the ingredient list, while “natural” as a claim on the food itself has never been defined by FDA rulemaking, and the Codex guideline that much of Southeast Asia works from defines natural and synthetic flavouring substances but has no definition of “nature identical” anywhere in it.

What a Flavouring Is Before It Is Natural

Start with what is being defined. Article 3(2)(a) of Regulation 1334/2008 sets out the object: “‘flavourings’ shall mean products: (i) not intended to be consumed as such, which are added to food in order to impart or modify odour and/or taste; (ii) made or consisting of the following categories: flavouring substances, flavouring preparations, thermal process flavourings, smoke flavourings, flavour precursors or other flavourings or mixtures thereof” A flavouring, then, is a product category rather than a single molecule, and the natural question attaches to the flavouring component, not to the finished food it goes into.

The EU Definition: Process and Origin

The EU definition of the natural building block itself, in Article 3(2)(c), is about process and origin: a natural flavouring substance means “a flavouring substance obtained by appropriate physical, enzymatic or microbiological processes from material of vegetable, animal or microbiological origin either in the raw state or after processing for human consumption by one or more of the traditional food preparation processes listed in Annex II. Natural flavouring substances correspond to substances that are naturally present and have been identified in nature” The last sentence is the one people miss. A molecule qualifies because it has been identified in nature and obtained from natural material by a listed process, not because it resembles something natural.

Naming a Source: the 95 Per Cent Floor

Naming a source is a separate and harder test. Article 16(4) provides that “The term ‘natural’ may only be used in combination with a reference to a food, food category or a vegetable or animal flavouring source if the flavouring component has been obtained exclusively or by at least 95 % by w/w from the source material referred to. The description shall read ‘natural “food(s) or food category or source(s)” flavouring’.” So “natural orange flavouring” carries a 95 per cent floor by weight of the flavouring component. Below that floor the Regulation supplies two alternative forms of words in Articles 16(5) and 16(6), one for a flavouring only partly derived from a recognisable named source and one for a flavouring drawn from several sources that no single name would describe. What the remaining five per cent may do is constrained, but by recital 26 rather than by Article 16: “As the use of flavourings should not mislead the consumer, the other maximum 5 % can only be used for standardisation or to give a, for example, more fresh, pungent, ripe or green note to the flavouring.” Cite the recital for that sentence, never the Article.

Article 16 Describes the Flavouring, Not Your Food

Article 16 also has a narrower reach than it is usually given. Article 16(1) provides that “If the term ‘natural’ is used to describe a flavouring in the sales description referred to in Article 15(1)(a) the provisions of paragraphs 2 to 6 of this Article shall apply.” The provisions govern the sales description of the flavouring. They are not a licence to describe the finished food as natural, and the two are routinely conflated.

The United States: Source, Not Chemistry

The United States builds the same word around source and process instead of a percentage. 21 CFR 101.22(a)(3) provides that “The term natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional.” Artificial flavour is then defined by exclusion rather than by chemistry, at 101.22(a)(1): “The term artificial flavor or artificial flavoring means any substance, the function of which is to impart flavor, which is not derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, fish, poultry, eggs, dairy products, or fermentation products thereof.” Note the consequence: a molecule can be chemically identical to one found in a strawberry and still be an artificial flavour, because the test is where it came from.

Why There Is No FDA Definition of 'Natural'

That is a definition of a flavour, not of a front-of-pack claim. On “natural” as a general food claim, FDA's own position is explicit: “Although the FDA has not engaged in rulemaking to establish a formal definition for the term "natural," we do have a longstanding policy concerning the use of "natural" in human food labeling. The FDA has considered the term "natural" to mean that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food.” The policy is expressly silent on processing and on health, as FDA says in the same place: “However, this policy was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation. The FDA also did not consider whether the term "natural" should describe any nutritional or other health benefit.” The rulemaking that might have settled it did not happen: “The comment period closed May 10, 2016. View submitted comments in docket folder FDA-2014-N-1207 on Regulations.gov.” So “natural flavor” in an ingredient list and “natural” on the front of a pack are different legal objects in the United States, and only the first is defined.

The Certification Your US Supplier Owes You

The US rules also put a documentary obligation on the supplier. 21 CFR 101.22(i)(4) provides that “A flavor supplier shall certify, in writing, that any flavor he supplies which is designated as containing no artificial flavor does not, to the best of his knowledge and belief, contain any artificial flavor, and that he has added no artificial flavor to it.” If a brief says no artificial flavour, that certification is the paperwork the claim runs on. In the ingredient list itself the declaration is short: 101.22(h)(1) permits that “Spice, natural flavor, and artificial flavor may be declared as “spice”, “natural flavor”, or “artificial flavor”, or any combination thereof, as the case may be.”

Codex Has No 'Nature Identical'

For much of Southeast Asia the reference standard is Codex, and Codex draws a two-way line. CAC/GL 66-2008 at 2.2.1.1 defines natural flavouring substances as “Natural flavouring substances are flavouring substances obtained by physical processes that may result in unavoidable but unintentional changes in the chemical structure of the components of the flavouring (e.g. distillation and solvent extraction), or by enzymatic or microbiological processes, from material of plant or animal origin. Such material may be unprocessed, or processed for human consumption by traditional food-preparation processes (e.g. drying, torrefaction (roasting) and fermentation). This means substances that have been identified / detected in a natural material of animal or vegetable origin.” and at 2.2.1.2 gives the counterpart: “Synthetic flavouring substances are flavouring substances formed by chemical synthesis.” Read the full guideline and there is no definition of “nature identical” and none of “artificial”. Its overarching test is honesty rather than origin: “The use of flavourings is justified only where they impart or modify flavour to food, provided that such use does not mislead the consumer about the nature or quality of food.”

Singapore Writes the Three-Way Split Into the Label

Singapore is the one market on this page where the three-way split is written into the label rule. First Schedule item 11 of the Food Regulations permits the generic term flavour or flavouring, qualified by the words natural, nature identical or artificial where one of them applies, and the item is quoted in full in our guide to Singapore flavour labelling. So “nature identical” is a permitted Singapore label qualifier even though Codex defines no such category. The underlying definitions sit in regulation 22. Regulation 22(6) provides that “Natural flavouring essences or extracts shall be preparations in any permitted solvent or any combination of permitted solvents, with or without sweeteners other than sweetening agents, permitted colouring matter or chemical preservatives, of sapid or odoriferous principles, or both, derived from a plant after which the flavouring extract or essence is named.”, which ties natural to the plant the essence is named after, and regulation 22(9) defines the synthetic side by origin: “Synthetic flavouring essences or extracts shall include any artificial flavour or imitation flavour which may resemble the sapid or odoriferous principles of an aromatic plant, fruit or vegetable or any other food, except that the flavouring principle shall be derived in whole, or in part, from either chemical synthesis or any other sources that does not involve extraction or isolation therefrom of the sapid or odoriferous principles present in an aromatic plant, fruit or vegetable or any other food.”

Australia and New Zealand Define It Nowhere

Australia and New Zealand are the outlier, because the Food Standards Code does not define the word at all. Standard 1.1.2 defines the object, “flavouring substance means a substance that is used as a food additive to perform the technological purpose of a flavouring in accordance with this Code.”, and Standard 1.2.4 governs how it is listed, but neither defines “natural” for a flavouring or contains the phrase “natural flavour”. A natural claim in those markets is therefore constrained by general misleading-conduct and fair-trading law rather than by the Code, which is a different body of law with different tests.

One Flavour, Four Answers

Put the four together and the same flavour can be described four different ways. In the EU it may be called natural only if its flavouring component is made up solely of natural flavouring substances and flavouring preparations, and may name a source only above 95 per cent by weight. In the United States it is a natural flavour if its constituents derive from the listed natural materials and its significant function is flavouring, with no percentage attached. In Singapore the ingredient list carries natural, nature identical or artificial as a qualifier where one of the three applies. In Australia and New Zealand the Code supplies no natural definition to satisfy. A brief that names every destination market before formulation begins avoids discovering this at the artwork stage.

What Singapore Said in May 2026

Two things happened in 2026 that a reader arriving from a news story will ask about, and neither changes a definition above. In Singapore, a parliamentary question on 6 May 2026 asked MOH to fold artificial flavours, colours and preservatives into the Healthier Choice Symbol or Nutri-Grade. MOH did not agree to, and drew the line that matters here: “Food additives, such as preservatives, colourings and flavourings are separately regulated by the Singapore Food Agency (SFA) for food safety purposes.” It added that “We will review the suggestions to consider possible refinements to our labelling schemes.” MOH has not ruled out a change and has not decided to grade flavours. In Singapore a flavouring is a safety matter for SFA and is not graded nutritionally, and there is no regulatory category called natural on the front of a pack.

The EU Union List Moved Both Ways

In the European Union the Union list moved in both directions on the same day, which is a clean illustration that authorised and natural are different axes. Commission Regulation (EU) 2026/172 of 26 January 2026 added a synthetic cooling substance, FL No 16.136, and corrected four CAS numbers that had been wrong in the list for flavouring substances FL Nos 08.017, 08.127, 16.041 and 16.132; that last detail is the argument for identifying a substance by its FL number rather than by its name. Regulation (EU) 2026/175 added hesperetin dihydrochalcone, FL No 16.137, at not more than 10 mg/Kg across fourteen categories. Meanwhile every smoke flavouring primary product has been deleted from the Union list, and the placing-on-the-market cut-off fell on 1 July 2026 for all food categories other than cheese, meat, processed fish and fish roe, which run to 1 July 2029. Authorised substances were added; a whole authorised category was withdrawn. Neither movement tells you whether anything is natural.

Vanilla pompona Joins FEMA 3105 and 3106

One change did touch what a natural identity covers. FEMA's Interim GRAS 32 list, published July 2026, records that “The botanical Vanilla pompona is also considered FEMA GRAS under the identities of FEMA 3105 and FEMA 3106”, which are vanilla extract and vanilla oleoresin, alongside Vanilla planifolia and Vanilla tahitensis. The same correction widened FEMA 2046, bitter almond oil, to cover Prunus armeniaca and Prunus persica. If your specification names a species, check it against the identity your supplier is actually working to. We set out how the commercial vanilla names sit against these definitions in our guide to vanilla extract versus vanilla flavour.

What Shoppers Say

The International Food Information Council's 2026 Food and Health Survey, fielded 22 March to 8 April 2026 with 3,005 respondents weighted to the American population, found natural named by 28 per cent as a definition of a healthy food and limited or no artificial ingredients or preservatives by 27 per cent, the latter up 10 points since 2022, with familiarity with the term ultraprocessed food at 52 per cent against 32 per cent in 2024. That is a United States sample with no South-East Asian or Australasian respondents. The percentages do not measure the views of Singapore or Jakarta shoppers.

Flavourings Are Counted as a UPF Input

A March 2026 analysis of thirty years of New Zealand trade data classifies flavourings inside the NOVA group 4 category, among the “food-derivatives/additives” that it calls ultra-processed food inputs, and reports that this subgroup's per-capita import volume has grown faster than any other ultra-processed subgroup since 2011. Whether a flavouring is natural, in any of the four senses above, does not change how that classification treats it.

Where Organic Fits

Organic is a separate certification regime sitting outside every definition on this page, so it belongs in the brief as its own line rather than as an extension of a natural claim. For where the commercial names sit against these definitions, see our guide to vanilla extract versus vanilla flavour.

How VKA Develops Natural Flavours

At VKA, we develop natural flavours from individual aroma chemicals derived from natural sources, matched by hand to your product's matrix and processing conditions. This is the molecular approach to natural flavour development: each natural compound is selected for its sensory contribution, then combined into a finished flavour that performs to specification through processing and on-shelf. Browse our Essences Portfolio for true-to-nature natural flavour profiles across citrus, vanilla, beef, chicken, coffee, tea, dairy, and cheese categories, or our Culinary Portfolio for natural flavours built from real vegetables, botanicals, herbs, and spices. For custom natural flavour development on your specific brief, talk to a flavourist directly.