Last updated on November 4, 2025
No. Under the Federal Food, Drug, and Cosmetic Act (FD&C Act), food labeling that is false or misleading—including misuse of the term “natural”—renders a product misbranded and illegal to sell. The FDA interprets “natural” to mean nothing artificial or synthetic has been added, while the FTC enforces against deceptive advertising. Violations can lead to warning letters, fines, product recalls, and litigation.
The Allure—and Risk—of “Natural”
In American supermarkets, “natural” is a powerful word. It evokes purity, simplicity, and health—qualities consumers crave. But behind that wholesome image lies a legal minefield. Unlike “organic,” which has strict USDA standards, “natural” remains loosely defined, creating room for interpretation—and abuse. Companies that stretch the meaning risk more than bad press; they face regulatory action and lawsuits.
What the Law Says
The Federal Food, Drug, and Cosmetic Act (21 U.S.C. §§ 301–399i) prohibits misbranding, which includes any false or misleading labeling. According to 21 CFR §101.18, a food is misbranded if its labeling creates a false impression about its ingredients or characteristics. This applies to claims like “natural” when the product contains artificial additives, synthetic preservatives, or other unexpected substances.
The FDA has not codified a formal definition of “natural,” but its longstanding policy interprets the term to mean that nothing artificial or synthetic has been included in, or added to, the food that would not normally be expected. This interpretation excludes considerations like pesticide use or genetic engineering, leaving gray areas that courts and regulators often scrutinize.
Meanwhile, the Federal Trade Commission (FTC) enforces truth-in-advertising laws under Section 5 of the FTC Act, targeting deceptive marketing practices. If a “natural” claim misleads consumers in advertising, the FTC can impose penalties or require corrective measures.
Why It Matters
Consumers pay premiums for “natural” products, believing they are healthier or less processed. Misleading labels erode trust and distort market competition. Regulators act to protect public confidence and ensure fair play. Recent enforcement trends show growing scrutiny of vague or exaggerated claims, especially as litigation over “natural” labeling surges.
Common Pitfalls for Brands
Many companies stumble by labeling products “natural” despite containing:
- Artificial flavors or colors
- Chemical preservatives
- Highly processed ingredients
Even if these additives are disclosed elsewhere on the label, the prominent “natural” claim can still mislead, triggering enforcement.
Consequences of Misbranding
Violations can lead to:
- FDA warning letters and mandatory label changes
- FTC enforcement actions for deceptive advertising
- Civil lawsuits and class actions seeking damages
- Product recalls and reputational harm
In severe cases, misbranding may result in criminal liability under the FD\&C Act.
Practical Guidance for Compliance
Brands should:
- Avoid “natural” claims unless the product meets FDA’s interpretation
- Maintain documentation proving ingredient integrity
- Consult legal counsel before marketing with “natural” labels
- Monitor FTC and FDA guidance for updates
Transparency isn’t just good ethics—it’s good business.
The Bigger Picture
The debate over “natural” reflects a broader challenge in food labeling: balancing marketing appeal with regulatory clarity. Until the FDA issues a formal definition, companies must tread carefully. For consumers, skepticism is wise; for brands, compliance is non-negotiable.
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Sources
Use of the Term Natural on Food Labeling – U.S. Food and Drug Administration
https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods/use-term-natural-food-labeling
Ongoing
eCFR :: 21 CFR 101.18 — Misbranding of food – Electronic Code of Federal Regulations
https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.18
Ongoing