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Keep It Clean

Albion Minerals®

Clean label,” a term used by food manufacturers and marketers, has increased its frequency in product development conversations. Not intended to be used in marketing messages, “clean” represents a constellation of attributes.

Ivan J. Wasserman, a partner with Washington, D.C.-based Manatt Phelps Phillips LLC, said there is no legal definition of “clean label,” and the term does not even have a universally accepted definition in the industry or among consumers.”I like to think of it as generally meaning a product that only contains ingredients that are easily recognized by consumers as things they are not afraid to eat.” He recalled the old television commercial of a child reading the label of a food product and not being able to pronounce the chemical ingredients.”That was an example of a label that was not ‘clean!’ While ‘clean’ is not synonymous with ‘natural,’ I think they are related.Generally, a clean label will not have artificial additives, especially colors and flavors.”

While there is no specific definition of the term, ingredient suppliers share similar ideas about its meaning. Leaslie Carr, marketing manager with Illinois-based Ingredion Incorporated (formerly Corn Products International), said in noting the growing demand, her company reviewed the market in order to propose defining clean label as “free from food additives, simple ingredient listing and minimally processed.”

Campbell Barnum, vice president of marketing with Kentucky-based D.D. Williamson (DDW), added: “A ‘clean label’ has a short, simple list of ingredients that are understandable to most consumers.” In a video interview for DDW’s “Expert Answers” series, David Schmidt, president and CEO of the International Food Information Council Foundation, addressed the question.There he said a clean label “describes a trend to reduce the number of ingredients used in a food product, and to have the ingredient names be more pronounceable for the average consumer reading the label … [It] does not relate to the safety of a product as any ingredient or color added to food must be deemed safe by the Food and Drug Administration before it is added to a food product.”

Studies Suggest Demand

According to the U.S. Trend Study by Health Focus International, 2011, 85 percent of consumers cite transparency as one of the most critical things they desire to create understanding and trust in what they are consuming, Carr pointed out.

“Retailers are no doubt key influencers in the clean label movement,” she said, “but consumers are also driving the trend. Again, it is access to information and the awareness of choices that have helped fuel the trend toward cleaner labels, and consumers associate natural with better for you.”

Dosage solution provider Capsugel, with world headquarters in New Jersey, helped to underwrite the Natural Marketing Institute’s Supplements/OTC/Rx Database (SORD) Study, which asked 2,355 U.S. adults questions about their use of supplements in 2011, noted Cliff Kendrick, business development manager, Health & Nutrition with Capsugel Americas Region.

Results of the study indicated that a growing number of supplement users- 42 percent-“worry about how a dietary supplement is made and if it contains tainted or illegal ingredients.” “That is a significant number,” Kendrick said.”Sixty-nine percent said they wanted to know the source of the ingredients, and 63 percent said they wanted their supplements from natural sources.”

Another important group stood out in the study. “The vegetarian-aware consumer highly correlates with label readers and heavy users of supplement products,” Kendrick added. “The number of this important vegetarian-preference shopper increased from 26 percent of the supplement user category in 2006 to 35 percent of that market in 2011. These are brand-loyal customers who use more supplements per day and spend more on supplements per day than the average supplement user. We think this valuable customer base and what it wants can be key influencers in the clean label product category.”

Jens Böhm, marketing manager with ingredient supplier BENEO (headquartered in Belgium with U.S. offices in New Jersey), agreed that today’s consumers are more educated when it comes to ingredients and food products. “With the current surge for living and eating healthy, the demand for clean labels and natural ingredients is expected to grow further. However, consumers tend to perceive foods being organic, natural or less allergenic also as ‘clean label,’ and thus better for you. However, ‘clean label’ is not necessarily linked to these benefits.”

All Natural?

As consumers look for ingredients they know and recognize, and turn from ingredients they do not understand, “clean” will vary from individual to individual; but in general, shorter labels and recognizable ingredients as well as positioning using terms such as “no additives,” “no preservatives,” “no artificial colors” are seen as indicators of clean label, said Carr.

As part of its continued and industryleading commitment to understanding consumer needs in clean label, Carr noted that Ingredion conducted the first in a new series of consumer research projects to identify global attitudes to clean label foods and beverages. “This global research project provides insights into the impact of product labeling on purchasing behavior in different regions and enables the company to make recommendations on how to cater for distinct requirements,” she added. Initial results will be available at www.cleanlabelinsights. com.

“Consumers consider clean label as those products with natural attributes as opposed to ‘all natural.’ In some channels, the ‘all natural’ designation might be more important-for example, in the traditional health food store,” added Kendrick. “But our observation is that in many cases, and channels, consumers are looking for products that don’t include preservatives, GMO ingredients, starches, gluten, allergens or other nonessential ingredients like fillers.”

The choice of natural attributes appears to be more important than organic and sustainable sourcing-40 percent vs. 30 percent and 28 percent, according to NMI SORD. “Those natural attributes include GMO-free, preservative- free and allergen-free. We see a reduction in soy and GMO as two of the largest trends today,” offered Kendrick.

Meeting Demand

To help manufacturers clean up their labels, suppliers are taking actions to meet the need. Along with Ingredion launching its “clean label” website, DDW has launched certified organic versions of both annatto extract and an acid-proof caramel color. “In addition to trade media, in the food ingredient sector, the most important trade events are IFT Food Expo and Food Ingredients Europe. Natural Products Expo West provides a good opportunity to see both suppliers and food manufacturers demonstrate the latest in natural trends,” said Barnum.

Böhm pointed out that major confectionery manufacturers are using rice starch as an alternative for titanium dioxide, which has been classified as “possibly carcinogenic to humans,” yet widely used as a whitener for confectionery, baked goods, cheeses, icings, toppings and food supplements, “Rice starches, such as BENEO’s Remy B7, are the perfect replacement for titanium dioxide.Due to the fact that it is a natural and healthy ingredient that is hypoallergenic, gluten-free and has a neutral taste, it is considered to support ‘clean label’ benefits.Healthier ingredient replacements such as these are the key to ‘cleaner’ labels.”

For global ingredient suppliers, an individual and local approach is certainly the key to success in promoting clean label initiatives due to very specific regulatory situations in every region, and the individual definitions of every manufacturer when it comes to this topic, according to Böhm. An example he offered is Nestlé UK: the company recently announced the replacement of all artificial flavors, colors and preservatives from its confectionery range. “How these communications are marketed and which benefits will be promoted remains to be seen,” Böhm said.

In addition, “manufacturers can adjust the contents of their products so they can remove label words that trigger negative consumer response,” said Capsugel’s Kendrick. “They can limit ingredients to commonly known, consumer- friendly ingredients. They can work to remove allergens, and thus allergen statements. They can eliminate GMO materials, reduce excipients and use natural colorants.”

He added that capsules in general offer the opportunity for a clean label, since they require fewer excipients, regardless of what they are, such as the bulking agents, lubricants, disintegrants, glidants and binders needed for tableting.”Capsules can be all natural or made with natural colorants, and require no preservatives and are free of allergens,” he said.

Capsugel has made a concerted effort to develop specific products for its customers to meet the growing demand for clean label products. For example, many of its customers were looking for acidprotection for sensitive ingredients like probiotics, but were not satisfied with the chemicals required to apply enteric coatings over their products. In response, Capsugel developed Drcaps™ capsules that use cellulosic HPMC, water and gellen gum to replace the compounds used in enteric manufacturing, yet they still offer a clean label while providing some protection that delays the capsule opening after swallowing for a more targeted release of ingredients. Drcaps capsules do not have the same finished properties as enteric capsules, but they still perform well, according to Kendrick.

Further, Capsugel’s liquid-filled Licaps® capsules use excipients that are hypoallergenic, such as sunflower lecithin rather than soy lecithin, to clean up allergen statements, Kendrick added. “We also work consistently to eliminate products with GMO concerns to provide a clean label.”

The company has a natural colorant portfolio including riboflavin, caramel and other colorants that are not FD&C dyes, and is currently working to expand this portfolio.

In addition, Capsugel recently introduced Plantcaps™ capsules, a pullulan capsule made from naturally fermented tapioca. According to the company, it is a more natural alternative pullulan capsule because it is the only pullulan capsule not made from cornstarch and thus an increasingly important choice as the interest in non-GMO sources grows.

Making a Statement

Like other claims, marketing messages discussing ingredients that are in (or that are not in) a dietary supplement, food or cosmetic product must be truthful and not misleading, noted Wasserman. “The FDA has rules with respect to nutrient content claims and standards or identity for certain ingredients,” he explained. “With respect to claims that a product does not contain a particular ingredient, marketers should be careful not to state or imply that the absent ingredient presents a greater health risk than is supported by good science. If the internet and blogosphere is ablaze with stories of health risks associated with an ingredient, it may be tempting to market a product as lacking that ingredient, but before you discuss the health effects of the ingredient, it is important to do your homework or you could hear from a regulator or a competitor.”

In addition to the FTC and FDA, it is important to keep in mind the National Advertising Division (NAD) of the Council of Better Business Bureaus, Wasserman added. “The NAD monitors advertising for supplements, foods and cosmetics, and can investigate ‘clean label’-type claims. If the advertiser does not make changes recommended by the NAD, it can refer them to the FTC or FDA for enforcement.” He also noted that class action attorneys have been active in bringing cases involving food-labeling claims, including ‘natural’ claims, or any claims that imply that a food is healthier than it is.

Many food companies look to Whole Foods Market’s published list of “unacceptable ingredients” for some guidance.Also terms such as “additive-free,” “preservative-free” and “no artificial colors” are easy to understand for consumers.At the other end of natural is organic, which is defined and regulated and can serve as a benchmark for what can define natural, Carr added.

“Clearer guidelines would be useful and help to reduce some of the confusion and distrust that may exist in consumers’ minds today,” she said.

“However, in the absence of a legal definition, food companies look to what resonates with consumers as well as what key influencers are promoting.”

Extra! Extra!

Visit www.niemagazine.com to read more about what Ingredion research found is considered “clean” by American and European consumers.


■ BENEO, (973) 867-2140
■ Capsugel Americas Region, (800) 845-6973
■ DDW, (502) 895-2438
■ Ingredion Incorporated, (708) 551-2600
■ LabelArchive, (208) 866-8839
■ Manatt Phelps Phillips, (202) 585-6529

Cloud-Based Labeling Provides for Quick Clean-Ups

Bill March, president of Idaho-based LabelArchive, said with the ongoing trend toward “clean labeling,” manufacturers and brand distributors will need to move swiftly to revise the way their labels are worded.

LabelArchive is a cloud-based software as a service (SaaS) that provides label managers with an interactive forum that links databases to a simple four-point workflow. The product blends a content management system (CMS) within a comprehensive order processing web-based workflow and allows label managers to pre-schedule orders and initiate and track all communication, editing, proofing and order placement activities.

“The text change handling capabilities of LabelArchive are a great example of the right tool becoming available when it is most needed by the industry,” said March.

“LabelArchive allows the user to compose and instantly preview an edit request and see all changed text and characters in highlighted form,” he explained. “No other CMS offers direct text changes that appear to all system users as highlighted within the surrounding text block.” This has only recently been made possible by software that is specially programmed to interact in The Cloud with a special Adobe server platform. The highlighting of the changed words leaves no question as to the content and location of the changed text. This composition and label preview is registered and saved so to be scrutinized by other stakeholders, then efficiently judged (accepted or declined) by a knowledgeable team leader. The team leader advances the order with all accepted text change requests on to a preassigned proofing team. The proofing team can also view, email or printout each highlighted edit request on a JPEG and PDF preview of the label in question.

LabelArchive’s text changing process does not require the time-consuming interplay with or services of a graphic artist. Direct graphic communication between the edit requester, the team leader and the proofing team means fewer mistakes and do-overs.

This change request and approval workflow substantially reduces the time and effort involved in processing content changes, according to March. With LabelArchive’s platform in The Cloud, any stakeholder can participate in the process at any time, in any location.

“Savings resulting from LabelArchive’s text change and highlighting functionality will certainly be substantial in a brand’s move toward clean labeling, but the efficiencies that are imbedded in LabelArchive’s order processing workflow also offer great on-going operational value,” March added.