Let's talk about "natural flavors!"
"Natural flavors" is a controversial ingredient in food because they can still contain a certain amount of synthetics like BHT, PEGs, and butylene glycol. But what about "natural flavors" in certified organic foods? Is there a difference?
Any flavor, natural or organic, in a certified organic product, can't contain those chemical additives and are in fact strictly regulated.
Organic Natural Flavors
In order to be considered certified organic, the organic natural flavor has to contain at least 95% organically grown ingredients. And contain no more than 5% non-organic ingredients in its composition. Any non-organic ingredient has to be on the national approved substances list. No ingredients can be made using synthetic extraction solvents or of synthetic origin. Organic flavors can’t contain any synthetic carriers or artificial preservatives. Certified organic natural flavors are non-GMO, grown without sewage sludge, and no ionizing radiation is used in their manufacturing process.
Organic natural flavors must be “from natural sources and have not been chemically modified in a way which makes them different than their natural chemical state” and are not allowed to be made with synthetic solvents or artificial preservatives.
What about non-organic "natural flavors" in a certified organic product?
Sometimes you'll see (non-organic) "natural flavors" in an organic product. Organic producers have to first look for an organic version of that particular flavor. If they're unable to find an organic version, a non-organic version can be used IF the non-organic version is a) free from synthetics b) Non-GMO c) not processed with ionizing radiation and d) not grown with sewage sludge. The total organic content of the finished product has to be 95% or more organic in order to bear the USDA organic seal, so the non-organic flavoring (and other non-organic ingredients that may be present) can't be more than 5% of the product.
Example
To explain how this works, let's pretend like we have an organic kombucha company. Let's say that we want to make a linden flower and goji berry flavored kombucha. Our formula uses linden flower and goji berries, but after the fermentation process, it doesn't leave us with much flavor. So to make an appealing product that people will buy again after trying, we want a nice flavor that really pops. After experimenting with juices and extracts, we realize that if we really want a flavor that shines, we need to add some flavoring.
So, first, we have to look for certified organic natural flavors to add to our product. Let's say we find a goji berry one that really works well. We get the organic certificate from the company, verify the organic certification and get the goji berry flavor added to our Organic System Plan. But we can't find an organic linden flower flavor to add a lovely hint of floral. So, we look for a non-organic version.
We find a linden flower flavor that we really like, we've finalized our formula with our winning flavor combination. Now, in order to use the non-organic linden flower non-organic natural flavor, we have to verify a few things. We need to first prove to our organic certifier that there isn't an organic version available. We take screen shots of the websites and product catalogs of the available organic suppliers showing that linden flower isn't part of their catalog. We also provide screen shots of web searches we've done, showing there are no organic options available.
Next, we need some documentation from the supplier. First, they need to verify that there are no synthetic ingredients in the flavoring, no preservatives, solvents, synthetics, etc. If it indeed meets this criteria, we then need to verify that there are no GMO inputs, no ionizing radiation was used on any input, and all of the ingredients were grown without sewage sludge. Our certifier may have us fill out a Natural Flavor Questionnaire to ensure all of the criteria are met.
If the company can provide all of this documentation, we then submit all of this paperwork to our organic certifier for approval. If the documentation is sufficient, they approve the product, provided the organic content is above 95% and meets all other organic certification requirements. Now we have our organic goji berry and linden flower kombucha approved and we can start selling it!
The ingredients label might read something like this:
"organic black tea, organic sugar, organic linden berry extract, organic goji berry juice, organic flavors, natural flavors."
Conclusion
Natural flavors found in a certified organic finished product (like a kombucha) are strictly regulated. Whereas, natural flavors in conventional products have little regulation and can contain synthetics.
More information: https://ota.com/sites/default/files/indexed_files/OrganicFlavorsPracticalGuidance_OrganicTradeAssociation.pdf
