Unraveling the Science of Clean Label Fats & Oils

Posted on:October 23, 2019

Selection of clean label alternatives for fat and oil ingredients depends on several factors. They include how the manufacturer defines clean label; the desired functionality of the ingredient in application; and physical properties, such as melting, crystallization or viscoelasticity. All of these factors are influenced by the ingredients’ chemical properties, explained Neil Widlak, MSc, Consultant, Fats and Oil Technologies in his presentation, “Factors to Be Considered for Selecting the Best Fats & Oils to Meet Clean Label Requirements.” Despite the considerations for use of such alternatives, from cost to quality to functionality, in the end, it all factors down to chemistry.

Triglycerides (TAG), esters of glycerol plus three fatty acids, form 98% of a fat’s composition, noted Widlak. The type of fatty acid—short carbon chain or long; degree of saturation (the higher the saturates, the more solid the fat); position of the fatty acids on the TAG molecule; and diversity of the TAG population—determines a fat’s properties and functionality. These properties can be changed through clean label process modifications, such as fractionation (e.g., physical rather than use of potentially objectionable solvents) and interesterification (e.g., use of enzymatic versus chemical hydrolysis).

While clean label, cold-pressed and/or expeller-pressed soybean and canola are readily available, they’re not available in the volumes (or prices) of commodity processed oils. And these alternatives may not be as easily interchanged, because of differences inherent in flavor and color—natural variances not removed during the “cleaner” extraction process. However, in terms of functionality, said Widlak, “Cold-pressed canola, expeller-pressed canola and organic canola have identical fatty acid composition vs. the commodity oil.”

A wide variety of fats can be produced with palm and cotton- seed oils through fractionation. “Clean label fluid shortenings, pumpable shortenings and oleogels can be used as alternatives for plastic/semi-solid fats in many baking applications, such as cakes, muffins, cookies, brownies. However, fluid, pumpable and oleogels lack the solids and structure of plastic shortenings and may not perform as well in applications where the plastic characteristics are essential to the distinct dough layers and volume found in puff pastries and Danish-type pasties,” offered Widlak. 

Palm kernel and coconut lipids, high in medium-chain saturated fatty acids, impart desirable quick melting at room temperature, but must be supplemented by the addition and or interesterification of fats having a higher melting range to achieve the desired melting range …to near body temperature to perform well in confections,” he added.

The goal of high performing shortenings or a confectionery shortening is dependent not only on its solid content and melting range, but also on the crystalline habit and behavior of the solid fats. All three characteristics must be examined and monitored throughout shelflife to ensure the shortening will meet a finished product’s performance standards.

Polyunsaturated fatty acids (e.g., linolenic [C18:3]) are more prone to oxidation and polymerization and should be kept to a minimum in oils used for frying or roasting, noted Widlak. Common varieties of soybean and canola oil contain high levels (greater than 2%) of linolenic fatty acids. High oleic varieties of these oils have been developed to lower the linolenic content and raise the oleic content, thus improving the oils frying, roasting and shelf-stability.

Research by the USDA indicates desirable fried food flavors are” contributed from the partial decomposition of linoleic (C18:2) fatty acids. Therefore, it may be advisable for oils used for frying to contain a portion of linoleic fatty acids to impart a desired fried food flavor. The ideal level would need to be determined based on the frying methods, type of food being fried and shelflife expectations,” Widlak noted.

Coconut oil does not form polymers/gums or an undesirable flavor from oxidation in popped corn because of its high levels of medium- chain saturated fat, which is very stable at high temperatures. Coconut oil is also an excellent oil for roasting, although foods with high moisture content could accelerate hydrolysis resulting in soapy off flavors in the roasted product and shorten shelflife, advised Widlak.

As he concluded, Widlak emphasized that oils, which are liquid at room temperature, cannot replace fats that are solid or plastic at room temperature and provide equivalent function/performance. It’s all a matter of understanding your application—and the chemistry within.

“Factors to Be Considered for Selecting the Best Fats & Oils to Meet Clean Label Requirements,” Neil Widlak, MSc, Consultant, Fats and Oil Technologies

This presentation was given at the 2019 Clean Label Conference. To download free presentations and the Post-conference summary of this event, go to

See past and future Clean Label Conferences at

Uncertain Clean Label Regulatory Environment

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Will FDA issue regulations defining natural and redefining healthy? Or will these claims become less common on food packages due to the risk of challenge? What are the implications for development of the clean label category, when ingredients disfavored by some consumers are important for taste, shelflife and even safety? Leslie Krasny, Partner, Keller and Heckman, LLP, considered these questions in a riveting and information-packed presentation on clean label complexities. The title of her talk was “The Impact of Regulatory Requirements and Litigation Risk on Clean Label Product Development and Marketing.”

“As we know, the concept of clean labels for foods has expanded to cover transparency, essentially creating a right-to-know expectation among consumers regarding disclosure of almost any information they may consider to be important,” she began. And, label challenges can be very costly and disruptive to manufacturers. The stakes are high but anticipating challenges can help mitigate or avoid such risks. Here are some highlights from her presentation.

At the Federal level, the FDA may cite label claims as violative in warning letters, which don’t represent final agency action but can trigger class action lawsuits. And all states have food laws that either incorporate the FDA’s labeling requirements or have similar requirements.

Regarding natural, the FDA’s informal policy defines the claim to mean that nothing artificial or synthetic (including all color additives, regardless of source) has been added to a food that would not normally be expected in that food. “The definition is ambiguous, and we have no idea what the last part means,” declared Krasny.

As for the USDA, meat, poultry and egg products typically have not been the subject of label claim challenges, because most claims must have prior approval from the USDA’s Food Safety and Inspection Service (FSIS). Under the USDA’s informal policy on natural, foods must contain no artificial or synthetic ingredients and also must be “not more than minimally processed.”

Unfortunately, said Krasny, plaintiffs often seek to apply the USDA’s “not more than minimally processed” criterion to FDA-regulated foods in challenging “natural” or “no artificial ingredients” claims. “Moreover,” she continued, “these definitions are not regulations, so there is no clear Federal preemption.”

Plaintiffs file lawsuits under state consumer protection laws for false, misleading or deceptive marketing, because there is no private right of action for consumers under the FDA and FTC regulatory frameworks. These federal and state laws apply a “reasonable person” standard. Some courts have opined that an interpretation of a claim may be considered “reasonable,” if held by a significant minority of consumers(12%). Courts often substitute their own judgments regarding whether interpretations are reasonable, and many class actions proceed based on the subjective views of the named plaintiffs.

What about terms that are arguably similar to healthy? In the final rule regarding that claim (decades ago), the FDA declined to define “wholesome,” “nutritious” and “good for you,” but stated that if these terms appear in association with nutrient content claims, the terms are implied nutrient content claims and unless defined by the FDA (which has not happened), could cause the products to be misbranded, Krasny stated. Plaintiffs have accused companies of creating misleading “healthy auras” through use of such terms when the healthy criteria are not met.

Class actions lawsuits for food labeling claims are trending upwards (a 9% increase in 2018 alone), but these statistics are just the tip of the iceberg, noted Krasny, because many challenges are settled privately for significant payments, often with label changes, with no complaints filed.

In her closing remarks, Krasny recommended making the legal review of label claims part of a company’s product development strategy early in the conceptualization process. “That way, you can make informed decisions based upon a company’s risk-management policy. Some companies are willing to assume high risks; others are very risk-averse.” Left unanswered was the question of whether it is better to avoid risky label claims altogether and just let clean ingredient statements do the talking. Cautioned Krasny: “Just be careful out there!

“The Impact of Regulatory Requirements and Litigation Risk on Clean Label Product Development and Marketing,” Leslie Krasny, Partner, Keller and Heckman, LLP.

This presentation was given at the 2019 Clean Label Conference. To download free presentations and the Post-conference summary of this event, go to

See past and future Clean Label Conferences at

Transitioning Omnivores Shift Toward Plant-Based Diets

Posted on:October 22, 2019

“Where does ‘science’ meet a company’s marketing objectives?” And, what does ‘clean label’ mean?” So enquired Rachel Cheatham, Ph.D., Founder & CEO, Foodscape Group, LLC in her presentation titled “Delivering Clean Label to the Transitioning Omnivore.”

“There are a lot of words to describe clean labels … ‘raw,’ ‘organic,’ ‘fresh,’ ‘natural,’… but there still exists no formal or regulatory definition of what it means,” she added. Cheatham cited a survey indicating that consumers generally associate clean label with organic labels (68%); with products found in the fresh foods sections of grocery stores (61%); and/or foods with ingredient labels containing only “recognizable” ingredients (58%).

Because the clean label term is not regulated, there are no fixed rules. This has spawned a wide variety of definitions and individual initiatives that can be contradictory and confusing. Major grocery (e.g., Kroger’s, H.E.B.) and restaurant (e.g., Panera) chains have responded by developing their own published definitions, listing ingredients that are either approved or not permitted in their categories.

The situation is further complicated by consumer confusion; Cheatham shared some outtakes from her LinkedIn commentaries. Some comments reflect fear and misinformation, such as: “Gums are lab formulated and come hidden in compound ingredients. Even a manufacturer doesn’t know of them.” Another comment was more ominously aimed at the processed foods industry: “Personally, I don’t care if a label is clean or not, because most of the food I buy has no label.”

Cheatham argued that the term clean label itself is too industry- focused. Consumers, she said, prefer to focus on “clean eating.” Citing a Nielsen study, she identified five label categories for foods: 1) conventional labels with no restrictions (a slightly declining category); 2) free-from labels, free of specific ingredients; 3) clean, defined as “free-from artificial and other objectionable ingredients;” 4) simple, containing only recognizable ingredients; and 5) sustainable. Sustainability, she said, was the fastest growing category, encompassing a smorgasbord of social justice criteria, ranging from non-GMO to workers’ rights.

From this foundational analysis, Cheatham segued to her organization’s Top10 Metatrends Report, a meta-analysis that draws a picture of a global omnivore diet transitioning away from animal proteins to plant-based diets, the subject of her presentation. She claimed that, today, “2-10% of any developed country’s population” is vegetarian, while estimating that “0.5% of the global population is vegan.” These numbers grossly underestimate the overall trend toward increased plant-based food consumption, she argued, as even dedicated omnivores are replacing more meat products with plant-based products in their daily diets. This trend has spurred the development of new, technology-based alternatives to harvested animal proteins.

As examples, she pointed to the “Beyond Burger®,” a plant-based beef burger substitute previously featured at the Global Food Forums conference. Although 100% plant- based, the product’s ingredient statement might not, at first glance, be viewed as clean label, so there are label trade-offs. Ocean Hugger Foods, Inc. created Ahimi™, a tuna substitute made from non-GMO vegetables, soy, sugar and sesame oil.

She also cited growing interest in animal cell-based (i.e., laboratory grown) meat technologies, noting global animal- protein giant Tyson Foods’ 2018 investment in Memphis Meats, a San Francisco-based start-up focused on laboratory-grown animal cell-culture products. In San Diego, BlueNalu is attempting to do the same with seafood proteins.

There has also been a proliferation of dairy product knockoffs, beginning with a plethora of nut, legume and cereal- based milks, but also cheese and yogurt substitutes.

While concluding, Cheatham re-minded audience members that there are always exceptions to ongoing trends: “Consumers make exceptions to their own rules and, sometimes, it is best not to tinker with proven-winner food products…clean label or no clean label. And, although clean label has no legal definition to date, this should not prevent companies from developing their own working definitions, thereof.”

It is complicated and challenging, she suggested, but “clean label efforts present an opportunity for greater internal alignment between Innovation/R&D and marketing communications.” Finally, she also proposed that company clean label policies be implemented enterprise-wide, rather than just at the SKU level.

“Delivering Clean Label to the Transitioning Omnivore,” Rachel Cheatham, Ph.D., Founder & CEO, Foodscape Group LLC

This presentation was given at the 2019 Clean Label Conference. To download free presentations and the Post-conference summary of this event, go to

See past and future Clean Label Conferences at

A Five-Step Approach to Certification of Food & Ingredient Supply Chains

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Mincing no words, Steve Taormina, Business Manager, NSF International, warned of major battles brewing in the food certification arena in his presentation “Behind the Label: Clean Label ‘Musts’ for the Ingredient Supply-Chain.” NSF International is a not-for-profit organization focused on science-based health and safety services that operates independently and is committed to professional certification. He emphasized, “NSF does not take positions on the merits of perceived public health issues, such as GMO or clean label definitions.”

Taormina warned that science is losing its battle to influence public perceptions on food safety risks, putting added pressures on food and beverage companies to comply with ever shifting and sometimes vague consumer expectations.

Taormina cited a 2018 PEW Research Center survey of 2,537 U.S. adults regarding their perceptions of food and beverage risks. While 70% of respondents acknowledged that science had had a “mostly positive effect” on foods, nearly 50% also expressed fears about the safety of food additives and claimed that GMO foods could lead to health or environmental problems.

Science and industry have been trying to push back by promoting uniform certification standards, such as the federal National Bioengineered Food Disclosure Standards. Independent groups, like the Non-GMO Project (Bellingham, Wash.) are writing their own standards for GMO-free food certification, with the ultimate goal of revolutionizing how foods are produced and processed worldwide, noted Taormina. Referencing “non-GMO” and “gluten-free” certifications, Taormina proposed a five-step approach toward companies’ certifications of their ingredient and food supply-chains.

Step one is to commit to full supply-chain transparency. “In the context of non-GMO standards, it all comes down to DNA verification,” expressed Taormina. Full transparency anticipates consumer expectations that all that is hidden will become exposed.

Step two is segregation of high-risk inputs. “For non-GMO certification, we know that minerals (salt, baking soda) have no DNA, so they can be overlooked,” said Taormina. “‘Low risk’ applies to crops and other ingredients not currently available in genetically modified forms. Most fruits and vegetables fall in this category, as do herbs and spices. ‘High-risk’ ingredients, on the other hand, include corn, soybean, canola, alfalfa, sugar beet, papaya, potato, squash/zucchini and ‘arctic apple,’ all of which may or may not include GMO variants. These warrant scrutiny,” he added

In order to comply with organizations such as the Non-GMO Project, one must be able to document the raw material sources of ingredients ranging from amino acids and flavors, to vitamins and the materials used in their processing. In the case of animal products, it also requires certifying the non-GMO status of feed ingredients…even the plants and flowers used to produce honey.

Step three is to establish, document and guarantee the traceability of ingredients all the way throughout the supply chain. Pointing to the ingredient list for a raspberry filling as an example, Taormina asked, “If it is sugar, is it made from beet or sugarcane? If citric acid, what was its raw material source? If flavors, what are their origins and methods and materials used in their extraction, and was the extraction material non-GMO?”

Step four is to ensure that allergen-control systems are in place to eliminate allergen risks. “What are the traceability protocols and operating procedures necessary to prevent commingling or cross-contamination by allergen or gluten-containing ingredients?” he asked.

Step five is to determine third-party certifications or the proper certification agencies with which to work. While certain retailers such as Whole Foods make clear their expectations, manufacturers face a plethora of choices. NSF is also working with the Plant Based Foods Association, an organization focused on providing vegan-friendly certification. Taormina anticipates some potential regulatory confusion regarding emerging plant-based products, given the liberal application of terms, such as “meat” and “milk” applied to plant-based products. Increasingly, companies must also deal with emerging consumer and retailer expectations regarding certifications pertaining to social justice issues, such as human and animal rights.

Remember, in the end, the goal of those seeking certification is not only about science, health or reason; it’s also about changing the face of global agriculture and the types of foods we eat.

“Behind the Label: Clean Label “Musts” for the Ingredient Supply- Chain,” Steve Taormina, Business Manager, NSF International

This presentation was given at the 2019 Clean Label Conference. To download free presentations and the Post-conference summary of this event, go to

See past and future Clean Label Conferences at

Flavor Use: Is Natural Necessarily Clean Label?

Posted on:October 20, 2019

“All natural” and “clean label” do not necessarily equate with one another, began Deepthi K. Weerasinghe, Ph.D., Principal, dP3 Consulting, in his presentation “Formation of Flavor—Is Natural the same as Clean Label?”

In the absence of a regulatory definition for clean label and only vague guidance by FDA and USDA as to what constitutes “natural flavor,” such determinations are widely subjective. His presentation outlined a growing struggle between existing and evolving flavor production technologies and regulatory strictures working hard to keep up with shifting consumer expectations.

So, what constitutes natural? To begin, raw plant and animal products have generally been accepted as “natural.” However, their naturalness immediately becomes subject to interpretation, depending on whether genetically modified organisms, pesticides, antibiotics and/or other chemicals were used in their production and handling. Aspergillus oryzae, for example, is a filamentous fungus used to produce soy sauce, miso and sake. The growth media for A. oryzae cultures can be manipulated to create lactones as flavoring compounds.

“Since they are produced through natural fermentation, the lactones would be considered natural at that point, as they are not all that different from other products of fermentation, such as beer, yogurt, bread or cheese,” said Weerasinghe. But what happens when one starts genetically manipulating the enzymatic components of fermentative microorganisms?

Weerasinghe noted a patented process that converts kaurenoic acid into steviol and rebaudioside(s) (sweet components from the stevia plant) using genetically modified microorganisms. Companies need to be alert to such developments and their implications for clean and/or natural label designations.

It is also possible to manufacture colors through genetic modification. Weerasinghe cited a technical paper outlining how four bioengineered microbes could be used sequentially to transform glucose into callistephin, an anthocyanin color found in strawberries, pomegranate and blue corn. Would clean label consumers deem such an ingredient natural?

A demarcation between “soft” vs. “hard” chemistry may also define what is natural. Weerasinghe noted that the flavor industry had contended with this issue years ago with hydrolyzed vegetable proteins (HVP). While initially manufactured using “hard” inorganic chemicals to hydrolyze the proteins into amino acid-based flavor enhancers, consumer pressure shifted the industry toward using natural enzyme-catalyzed hydrolyses (i.e., “soft” chemistry).

This demarcation may not be quite so clear-cut today, especially under more restrictive EU regulations, said Weerasinghe. “Soft chemistry also refers to processing methods similar to common kitchen practices,” explained Weerasinghe, as in the use of juice concentrates and heat to manipulate pH conditions. Weerasinghe pointed to a patent describing the production of aliphatic alcohols and aldehydes from vegetable oils using enzymes naturally present in guava juices and soy flour. But, even then, he said, “The methodology used to extract and purify such enzymes will factor into their regulatory and clean label designations.”

The types of flavor extraction processes used also impact natural label designations. It makes a difference, he noted, if flavors are extracted with water, with ethanol (tinctures), or with natural oils or organic chemical solvents (oleoresins). Vanilla extractions typically use ethanol and water. However, the U.S. Code of Federal Regulations (CFR) also allows the use of glycerin, propylene glycol, sugar, dextrose and corn syrup in such extractions. Even such minor extraction-process modifications that could ultimately affect label designations.

Processed flavors, which rely on Maillard reactions and Strecker degradations to produce savory flavors, are regulated in terms of process conditions (temperature, time, raw materials) to determine what constitutes natural. In the EU, they must be called “processed flavors.” But their appeal also lies in the ability to create vegan meat flavors from vegetable proteins. “You can make a wide range of chicken or beef flavors without using animal proteins,” said Weerasinghe.

Whether or not they qualify as natural or clean label will depend upon both regulatory authorities—and where vegan consumers are willing to accept trade-offs
“Clean label folks don’t like black box ingredient designations like ‘natural flavors,’ because it doesn’t tell them what is in there,” concluded Weerasinghe. “Customers today are looking for safety; many are looking for comfort. Many customers have health challenges; they want protection from the unknown.”

The question remains: Are regulatory environments helping or hurting such aspirations?

“Formation of Flavor—Is Natural the Same as Clean Label,” Deepthi K. Weerasinghe, Ph.D., Principal, dP3 Consulting

This presentation was given at the 2019 Clean Label Conference. To download free presentations and the Post-conference summary of this event, go to

See past and future Clean Label Conferences at

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