The following shows the exact email response I was given permission to use on my site. I have removed some name info and email bits to stop slow the spam and provide a bit of privacy for all involved.
----Original Message-----
From: Aubrey <aubrey at arborteas.com>
To: delightfulrepast <delightfulrepast at aol.com>
Sent: Wed, Oct 25, 2017 3:05 pm
Subject: Re: Earl Grey Labeling Suggestion
----Original Message-----
From: Aubrey <aubrey at arborteas.com>
To: delightfulrepast <delightfulrepast at aol.com>
Sent: Wed, Oct 25, 2017 3:05 pm
Subject: Re: Earl Grey Labeling Suggestion
Hi Jean -
Hello from Aubrey at Arbor Teas! Jeremy and Chelsea forwarded your message to me as I handle our labeling and certifications. Thanks so much for the suggestion and I'm completely on board with your desire for a more transparent labeling of flavors. However, as with everything, it is unfortunately not that simple. And there is a lot of confusion and misunderstanding in the marketplace.
This is probably way more info than you want, but here are a couple key concepts that are important to keep in mind:
1) There are specific requirements by the FDA for how a flavor may be listed on an ingredients label. This explains why we list flavors in our ingredients using very precise language and cannot use words such as "real". In 2014 the Food and Drug Administration (FDA) revised the labeling regulations for spices, flavorings, colorings and chemical preservatives for foods. In 21CFR101.22(h) it states: "The label of a food to which flavor is added shall declare the flavor in the statement of ingredients in the following way: Spice, natural flavor, and artificial flavor may be declared as "spice", "natural flavor", or "artificial flavor", or any combination thereof."
2) There are three (3) main types of flavors: natural flavors; artificial flavors; and nature identical flavors. Most of the misunderstanding in the market place is caused by confusion of these terms, particularly "natural flavors" and "nature identical flavors". Keep in mind that the FDA has very specific definitions for these terms. But in basic terms:
Natural Flavors are ingredients that come from natural sources such as spices, fruits, vegetables, herbs, barks, roots, meats, seafood, poultry, eggs, and dairy products.
Artificial Flavors are chemical compounds created to mimic a natural flavor.
Nature Identical Flavors are chemical compounds that are created to have the same chemical composition as natural flavors and also taste and smell just like them; however they are not derived from the original spice, fruit, etc.
All flavors are created through some processing and most are indeed created in a food processing facility or "lab" because the equipment required to extract oils and flavors is often very expensive and requires controlled environments. Very few flavors can be extracted by simple pressing. However, in the US a "natural flavor" must always be extracted from the original botanical. If a flavor is created in a lab to mimic the chemical composition as the botanical (but not extracted from the original botanical) the flavor is actually a "nature identical flavor." In Europe, "nature identical flavors" are listed as "natural flavors" on ingredient labels. In the US "nature identical flavors" are listed as "artificial flavors". As a result, you can rest assured that in the US flavor formulations solely created in a petri-dish cannot be listed on ingredient labels as "natural".
However, you are correct that numerous solvents and carrier agents can be added to a "natural flavor" to help extract and/or preserve the "natural flavor". This, I believe, is your main concern and the main concern in the piece that you cut and pasted from the internet in your email. I have good news for you....
3) The term "natural flavor" or “natural flavors” is a term that is highly regulated in USDA organic certified food production. In USDA organic certified products (such as ours) all flavors must be derived from a botanical and must be organic compliant with strict limitations on any solvents or additional carrier agents. Synthetically derived (or artificial) flavors and artificial preservatives are prohibited. The natural flavors we use in our flavored teas at Arbor Teas are extracts taken directly from the botanical with no additional carrier agents or solvents, or taken from the botanical with only the use of 100% GMO-free grain alcohols as a solvent. In non-organic certified products other solvents or carrier agents can be used, but in USDA organic-certified food production they cannot. This is yet another reason to chose organic!
Finally -- a quick note about Nature Identical Flavors. This flavor category often gets a bad rap in the US and is even prohibited in organic certification (so Arbor Teas can't use them). However, in the world of sustainability there is a lot of discussion surrounding "natural flavors" and "nature identical flavors." The creation of "natural flavors" requires a huge amount of raw materials and energy. Some argue that the raw materials used to create a "natural flavor" would be better consumed as "food" rather than used to create a "flavor". As a result, many argue (including those in Europe) that the utilization of nature identical flavors not only preserves the natural resources of the most popular and most frequently used raw materials for natural flavoring, but maintains the same chemical composition, same taste, and same smell over longer storage periods. So, from a pure food supply argument, nature identical flavors may be in our future....
Hello from Aubrey at Arbor Teas! Jeremy and Chelsea forwarded your message to me as I handle our labeling and certifications. Thanks so much for the suggestion and I'm completely on board with your desire for a more transparent labeling of flavors. However, as with everything, it is unfortunately not that simple. And there is a lot of confusion and misunderstanding in the marketplace.
This is probably way more info than you want, but here are a couple key concepts that are important to keep in mind:
1) There are specific requirements by the FDA for how a flavor may be listed on an ingredients label. This explains why we list flavors in our ingredients using very precise language and cannot use words such as "real". In 2014 the Food and Drug Administration (FDA) revised the labeling regulations for spices, flavorings, colorings and chemical preservatives for foods. In 21CFR101.22(h) it states: "The label of a food to which flavor is added shall declare the flavor in the statement of ingredients in the following way: Spice, natural flavor, and artificial flavor may be declared as "spice", "natural flavor", or "artificial flavor", or any combination thereof."
2) There are three (3) main types of flavors: natural flavors; artificial flavors; and nature identical flavors. Most of the misunderstanding in the market place is caused by confusion of these terms, particularly "natural flavors" and "nature identical flavors". Keep in mind that the FDA has very specific definitions for these terms. But in basic terms:
Natural Flavors are ingredients that come from natural sources such as spices, fruits, vegetables, herbs, barks, roots, meats, seafood, poultry, eggs, and dairy products.
Artificial Flavors are chemical compounds created to mimic a natural flavor.
Nature Identical Flavors are chemical compounds that are created to have the same chemical composition as natural flavors and also taste and smell just like them; however they are not derived from the original spice, fruit, etc.
All flavors are created through some processing and most are indeed created in a food processing facility or "lab" because the equipment required to extract oils and flavors is often very expensive and requires controlled environments. Very few flavors can be extracted by simple pressing. However, in the US a "natural flavor" must always be extracted from the original botanical. If a flavor is created in a lab to mimic the chemical composition as the botanical (but not extracted from the original botanical) the flavor is actually a "nature identical flavor." In Europe, "nature identical flavors" are listed as "natural flavors" on ingredient labels. In the US "nature identical flavors" are listed as "artificial flavors". As a result, you can rest assured that in the US flavor formulations solely created in a petri-dish cannot be listed on ingredient labels as "natural".
However, you are correct that numerous solvents and carrier agents can be added to a "natural flavor" to help extract and/or preserve the "natural flavor". This, I believe, is your main concern and the main concern in the piece that you cut and pasted from the internet in your email. I have good news for you....
3) The term "natural flavor" or “natural flavors” is a term that is highly regulated in USDA organic certified food production. In USDA organic certified products (such as ours) all flavors must be derived from a botanical and must be organic compliant with strict limitations on any solvents or additional carrier agents. Synthetically derived (or artificial) flavors and artificial preservatives are prohibited. The natural flavors we use in our flavored teas at Arbor Teas are extracts taken directly from the botanical with no additional carrier agents or solvents, or taken from the botanical with only the use of 100% GMO-free grain alcohols as a solvent. In non-organic certified products other solvents or carrier agents can be used, but in USDA organic-certified food production they cannot. This is yet another reason to chose organic!
Finally -- a quick note about Nature Identical Flavors. This flavor category often gets a bad rap in the US and is even prohibited in organic certification (so Arbor Teas can't use them). However, in the world of sustainability there is a lot of discussion surrounding "natural flavors" and "nature identical flavors." The creation of "natural flavors" requires a huge amount of raw materials and energy. Some argue that the raw materials used to create a "natural flavor" would be better consumed as "food" rather than used to create a "flavor". As a result, many argue (including those in Europe) that the utilization of nature identical flavors not only preserves the natural resources of the most popular and most frequently used raw materials for natural flavoring, but maintains the same chemical composition, same taste, and same smell over longer storage periods. So, from a pure food supply argument, nature identical flavors may be in our future....
Hope this helps to clarify a few things! However, if you have any other questions feel free to reach out.
All best,
Aubrey
Arbor Teas
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