Unlike "gluten-free," which has a precise regulatory definition under 21 CFR 101.91, "natural" exists in a regulatory gray zone. The FDA has declined multiple times to establish a formal definition for the term on food and supplement labels, most recently in 2016 when it closed a comment period without issuing a final rule.
The result: brands can use "natural" on supplement labels without violating any specific FDA regulation — but they do so in an environment where the claim is heavily litigated by class action plaintiffs, scrutinized by the FTC, and evaluated by retailers who have their own standards.
The FDA's Position on "Natural"
The FDA's informal policy, articulated in guidance documents and enforcement letters, is that it has generally not objected to the use of "natural" when a product contains no artificial or synthetic ingredients and no color additives. This is an informal policy, not a regulation — meaning it's not legally binding and doesn't protect brands from non-FDA enforcement.
The FDA has consistently stated it may revisit this position, and it has used the unfair or deceptive practices framework to challenge "natural" claims in specific enforcement contexts — particularly when a product contains ingredients that a reasonable consumer would consider artificial.
What Triggers Class Action Litigation
Class action lawsuits over "natural" claims typically target supplements and foods that contain one or more of the following:
Synthetic ingredients presented as natural (synthetic vitamins, artificial colors, synthetic preservatives)
Highly processed ingredients whose natural origin is no longer recognizable (high fructose corn syrup, certain protein isolates processed with chemical solvents)
Pesticide residues on ingredients represented as naturally grown
GMO-derived ingredients — particularly soy, corn, or canola — where plaintiffs argue consumers understand "natural" to exclude GMOs
Chemically extracted compounds like certain botanical extracts processed using hexane or other synthetic solvents
Courts have been inconsistent in ruling on these cases. Some have found that "natural" claims are preempted by federal law; others have allowed state consumer protection claims to proceed. The litigation risk is real and ongoing — and settlements can be significant.
The FTC's Approach
The FTC's general advertising standards under Section 5 of the FTC Act require that all claims be truthful and not misleading. For "natural" claims, the FTC has indicated it evaluates whether the claim is likely to mislead a reasonable consumer — which means the agency looks at what consumers actually understand "natural" to mean.
FTC guidance on environmental marketing (the Green Guides, 16 CFR Part 260) provides some analogous principles: unqualified claims are interpreted broadly, and if a claim can be understood in multiple ways, it's judged against its broadest reasonable meaning. Applying that logic to "natural," a brand that uses the term on a supplement containing synthetic excipients may be making a claim that misleads consumers — regardless of whether the active ingredients are plant-derived.
Retailer Standards for "Natural"
Major natural grocery retailers — Whole Foods, Natural Grocers, Sprouts, and others — have their own "Unacceptable Ingredients" lists that effectively define what qualifies as natural for products on their shelves. These retailer standards often go beyond FDA's informal guidance and may exclude:
Synthetic sweeteners
Artificial colors and flavors
Certain preservatives
High fructose corn syrup
Partially hydrogenated oils
Certain synthetic processing aids
A supplement that passes FDA's informal "natural" standard might still be removed from a natural channel retailer's shelves if it contains an ingredient on their prohibited list. For brands selling in the natural channel, retailer compliance with category-specific standards is practically as important as regulatory compliance.
The "All Natural" vs. "Natural" Distinction
"All natural" is a stronger claim than "natural" and carries correspondingly higher litigation risk. Courts and the FTC evaluate unqualified absolute claims — "all natural" implies that everything in the product is natural, with no exceptions. A single synthetic ingredient can undermine the entire claim.
Qualified claims ("made with natural ingredients," "naturally flavored") are generally lower-risk because they're more specific and less absolute — though they're still subject to consumer understanding standards.
"Natural" is a marketing claim that requires legal discipline
The absence of an FDA definition doesn't mean "natural" is a free claim. It means the risk is distributed differently — across civil litigation rather than regulatory enforcement. Brands using "natural" claims should audit their formulations against consumer expectation standards, retailer requirements, and FTC guidance before the claim appears on a label or in advertising. Truli's product compliance scans flag "natural" claim risks in the context of your full formulation — including synthetic processing aids, excipients, and ingredients that may be naturally derived but synthetically processed.
A note from Truli: Truli is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
