Natural Flavour Labelling: FDA vs EU Rules Compared

What counts as a natural flavour in the US and EU?

Both markets use the word “natural”, but it does not mean the same thing on a label. In the US it is a source-based definition inside the flavour labelling rule.^[1] In the EU it is a controlled descriptor tied to the type of flavouring, how it was made and how much comes from a named source, and it sits beside a general ban on misleading food information.^[2][3]

The artificial vs natural flavour split also differs. The US defines “artificial flavor” as any flavouring substance not derived from the listed sources.^[1] EU consumer labels do not use “artificial” at all: a flavouring is declared as “flavouring” unless it meets the criteria for “natural”.^[3] This guide compares the two rulebooks for natural flavour labelling. For the US definition in depth and what the safety evidence shows, see FRL’s explainer What are natural flavors?

A “natural flavor” declaration is also not the same as a “natural” product claim. FDA has no formal definition of “natural” for a front-of-pack claim and relies on a long-standing policy that nothing artificial or synthetic, including any colour additive, has been added that would not normally be expected in the food.^[8]

US rules: the FDA natural flavor definition (21 CFR 101.22)

Under 21 CFR 101.22(a)(3), a natural flavour is the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis that contains flavouring 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 their fermentation products, and whose significant function in food is flavouring rather than nutritional.^[1]

Two practical points follow. Derivation is what matters: a flavour made from a listed source by roasting, heating or enzymolysis can still be natural. And the source need not be named in the ingredient list, where “natural flavor” is enough.^[1] Safety sits outside this labelling rule, through GRAS status or food additive approval.^[4]

Characterising flavours and WONF

When the label represents a flavour, in words or with a picture such as a fruit, paragraph (i) sets how the product name must read:^[1]

• Natural flavour only, no artificial flavour: the name carries the flavour, for example “vanilla”. If the food is expected to contain the ingredient (strawberries in strawberry shortcake) but holds too little to characterise it, or none, the flavour name is followed by “flavored”: “strawberry flavored shortcake” or “natural strawberry flavored shortcake”.
• Flavour from the named food plus other natural flavours that reinforce it: the name is followed by “with other natural flavor”, the origin of the industry shorthand WONF.
• No natural flavour from the named food: the food is labelled with the flavour of the actual source, or as “artificially flavored”.
• Any artificial flavour that simulates or reinforces the characterising flavour: “artificial” or “artificially flavored”, for example “artificially flavored strawberry”.

The flavour wording must be at least half the height of the letters in the food name, or in the flavour name for “flavored” and WONF.^[1]

EU rules: natural flavourings under Regulation (EC) No 1334/2008

Regulation (EC) No 1334/2008 defines flavouring substances, flavouring preparations and other flavouring categories. A natural flavouring substance is obtained by appropriate physical, enzymatic or microbiological processes from material of vegetable, animal or microbiological origin, and corresponds to a substance that is naturally present and has been identified in nature.^[2] Flavouring substances may be used only if they are on the Union list, adopted by Regulation (EU) No 872/2012 after safety evaluation.^[5] On consumer labels, Regulation (EU) No 1169/2011 requires flavourings to be declared as “flavouring(s)” or by a more specific name or description, and “natural” may be used only as Article 16 of Regulation 1334/2008 allows.^[3]

Article 16: when “natural” and a named source are allowed

• “Natural” flavouring: only if the flavouring component consists solely of flavouring preparations and/or natural flavouring substances (Art. 16(2)).
• “Natural flavouring substance(s)”: only if the flavouring component contains natural flavouring substances alone (Art. 16(3)).
• “Natural [source] flavouring”, such as “natural strawberry flavouring”: at least 95% by weight of the flavouring component must come from the named source. The remaining 5% or less may be used only to standardise the flavour or to give, for example, a fresher, pungent, ripe or green note (Art. 16(4)).
• “Natural [source] flavouring with other natural flavourings”: when the named source contributes only partly but its flavour is easily recognisable (Art. 16(5)).
• “Natural flavouring” alone: when the flavouring comes from several sources and naming them would not reflect the taste (Art. 16(6)).

The named source’s flavour therefore has to be genuine and measurable from the composition, not implied by the recipe name.^[2]

What has changed: dates and current status

The EU regulation has been amended many times since 2008, mostly to update the Union list, and EUR-Lex publishes consolidated versions. At the time of writing the latest is dated 16 February 2026; the one before it is dated 25 June 2025.^[6][9] Check the latest consolidated text, not the 2008 Official Journal version, before finalising artwork.

In the US, 101.22 is read from the current eCFR.^[1] The natural flavor definition has not changed, but on 11 August 2026 FDA proposed making GRAS notification mandatory for substances used in human and animal food, with comments due by 9 December 2026.^[7] That would affect the safety route for flavour ingredients, not the labelling words.

FDA vs EU: the key differences compared

Under the FDA rule the test is derivation and function; under the EU regulation it is the type of flavouring, how it was made and the declared name. The practical result is that identical flavour chemistry can carry different words, and sometimes different claims, on either side of the Atlantic.

Table 1. FDA and EU natural flavour rules compared

Labelling one product for both markets

Take a strawberry yogurt that holds too little fruit to characterise it on its own, flavoured with strawberry extract and possibly other flavourings. Table 2 shows how the wording changes with the flavour recipe. In the US ingredient list the flavour reads “natural flavor” in the first three rows and “artificial flavor” in the last; it is the product name that changes. In the EU it is the flavouring declaration that changes.^[1][2][3]

Table 2. Worked label examples for one flavoured yogurt

For supplier control, the workflow means asking each flavour supplier for origin, process and composition by weight, because the 95% test cannot be checked from a trade name. FRL’s sensory research and analytics team can confirm that a named-source flavour is actually perceptible and benchmark it against the market, while label wording is checked separately for each market.

Table 3. Compliance requirements and business impact

Formulator’s note: build the 95% check into supplier specifications. Ask each flavour supplier for the origin and weight share of any named source, so the EU wording is decided at specification stage, not at artwork stage.

Common natural flavour labelling mistakes

• Reusing US wording on EU packs, where “natural flavor” is not the EU form; EU lists say “flavouring” or use the Article 16 wording.^[3][2]
• Naming a source in the EU without confirming the 95% threshold.^[2]
• Calling a blend “natural” in the EU when one component is not a natural flavouring substance or flavouring preparation.^[2]
• Calling a US product “strawberry yogurt” when the strawberry taste comes mainly from flavouring rather than fruit, instead of “strawberry flavored”.^[1]
• Missing WONF wording where other natural flavours reinforce the characterising flavour.^[1]
• Letting the front-of-pack flavour claim and the ingredient list disagree.
• Treating legal “natural” wording as a sensory claim. Taste and “real flavour” claims need their own evidence, as set out in ISO 20784, and FRL’s guide to sensory evaluation of food explains how that evidence is built.^[10]

When a flavour defect reaches consumers, the route from complaint to withdrawal is covered in off-odour and taint food recalls. For another dual-market labelling comparison, see probiotic claims in the EU and US.

Conclusion

The FDA natural flavor definition rests on source and function, while EU rules add limits on the type of flavouring and a 95% test for naming a source, so natural flavour labelling cannot be copied between markets. Get origin and composition data from suppliers, apply each market’s declaration and naming rules, and have the final label reviewed for each market before artwork is signed off.

For brands & formulators

Food Research Lab helps brands label one flavoured product for both the US and the EU from our base in Chennai, India. Our regulatory and scientific research team reviews flavour specifications, supplier origin and composition data, and ingredient-list and front-of-pack wording against 21 CFR 101.22 and Regulation (EC) No 1334/2008. Our sensory research and analytics team checks that a named-source flavour is perceptible, with panels we run or arrange through accredited partner laboratories, and our new food product development team reformulates where a flavour cannot meet a market’s rules.

Send your recipe, flavour specifications and target markets through our contact page.

In this series

This guide is part of FRL’s sensory and flavour series for US and EU brands. Read on in this order:

• Flavour trends 2026: swicy, botanicals and global heat in the US and EU.
• Natural flavour labelling: FDA vs EU (you are here): how one flavour is worded for each market.
• Off-odour and taint food recalls: how sensory failures become withdrawals in the US and EU.
• Designing a sensory study: the hub guide to tests, panels and statistics.
• Flavour validation with sensory panels: a worked example from trained panel to consumer test.
• Sensory testing regulations in the US and EU: common questions answered.
• Sensory research and analytics: work with FRL on panels, consumer tests and flavour validation.

1. U.S. Food and Drug Administration. (2026). 21 CFR § 101.22: Foods; labeling of spices, flavorings, colorings and chemical preservatives. Electronic Code of Federal Regulations. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-B/section-101.22 (cited for the natural and artificial flavor definitions in (a)(1) and (a)(3), ingredient declaration in (h)(1) and characterising-flavour wording in (i))
2. European Parliament & Council of the European Union. (2008). Regulation (EC) No 1334/2008 on flavourings and certain food ingredients with flavouring properties for use in and on foods (Official Journal L 354, 31.12.2008). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2008/1334/oj/eng (cited for the definitions in Article 3, Article 16 on the term ‘natural’, and application from 20 January 2011)
3. European Parliament & Council of the European Union. (2011). Regulation (EU) No 1169/2011 on the provision of food information to consumers. EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011R1169 (cited for Article 7 fair information practices, Annex VII Part D designation of flavourings, and application from 13 December 2014)
4. U.S. Food and Drug Administration. (2026). 21 CFR § 170.30: Eligibility for classification as generally recognized as safe (GRAS). Electronic Code of Federal Regulations. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-170/subpart-B/section-170.30 (cited for the GRAS safety route, separate from labelling)
5. European Commission. (2012). Commission Implementing Regulation (EU) No 872/2012 adopting the list of flavouring substances provided for by Regulation (EC) No 2232/96. EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0872 (cited for the Union list of flavouring substances, applicable from 22 April 2013)
6. European Commission. (2026, February 16). Consolidated text: Regulation (EC) No 1334/2008 (CELEX 02008R1334-20260216). EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008R1334-20260216 (cited as the latest consolidated version at 10 November 2026)
7. U.S. Food and Drug Administration. (2026, August 11). Substances generally recognized as safe [Proposed rule]. Federal Register, 91, 51834 (Docket No. FDA-2025-N-3262). https://www.federalregister.gov/documents/2026/08/11/2026-16296/substances-generally-recognized-as-safe (cited for the proposal to make GRAS notification mandatory; comments due 9 December 2026)
8. U.S. Food and Drug Administration. (2018). Use of the term “natural” on food labeling. https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods/use-term-natural-food-labeling (cited for FDA’s long-standing ‘natural’ claim policy and the absence of a formal definition)
9. European Commission. (2025, June 25). Consolidated text: Regulation (EC) No 1334/2008 (CELEX 02008R1334-20250625). EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008R1334-20250625 (cited as the previous consolidated version)
10. International Organization for Standardization. (2021). ISO 20784:2021 Sensory analysis: Guidance on substantiation for sensory and consumer product claims. https://www.iso.org/standard/69080.html (cited for evidence behind taste and ‘real flavour’ claims)