The regulatory definition of natural flavor
Under 21 CFR 101.22, a natural flavor is defined as the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating, or enzymolysis that is derived from a plant, animal, seafood, poultry, or dairy product — and whose function is flavoring rather than nutritional. The source of the flavor compound has to be a natural starting material, but the processing steps to extract and concentrate that compound can be extensive. Natural vanilla flavor, for example, can involve significant processing of vanilla bean extract. What matters is the source, not the simplicity of the manufacturing process.
What artificial means
An artificial flavor is any flavor compound not meeting the natural definition — typically synthesized from petrochemical precursors rather than derived from natural starting materials. Ethyl vanillin, the most common synthetic vanilla compound, is made from guaiacol derived from petroleum. It is not a natural flavor. Vanillin derived from the fermentation of ferulic acid from rice bran can be labeled natural because the source is natural. The compound is identical. The label is not.
Natural and artificial: the practical middle ground
Natural and artificial (N&A) flavors combine both types in one formulation. This declaration is commonly used when a natural base provides the primary character and a synthetic compound is added for cost, stability, or intensity reasons. An N&A strawberry flavor might use natural strawberry extract for authentic character and add synthetic ethyl acetate to boost the top note at a fraction of the cost of additional natural extract.
N&A is often the most practical starting point for applications where natural declaration is preferred but cost is constrained, or where a full natural formula cannot achieve the target intensity or stability profile.
Cost implications
Natural flavors almost always cost more than their artificial equivalents. The sourcing of natural raw materials, extraction processes, and the inherent variability of natural inputs all contribute to higher cost. The premium for natural declaration varies enormously by flavor: natural vanilla is significantly more expensive than vanillin; natural mint costs modestly more than synthetic menthol. For budget-constrained projects, N&A formulation often achieves a label that reads "natural and artificial flavors" at a meaningfully lower cost than all-natural.
What you can and cannot claim
The label declaration ("natural flavors," "natural and artificial flavors," or "artificial flavors") is determined by the flavor supplier based on the ingredients in the formula. The finished product label must accurately reflect the declaration type of each flavor used. If your formula contains an N&A flavor, you cannot label the finished product as containing only "natural flavors." This sounds obvious but creates problems when reformulations change declaration type mid-development without updating the label review. Confirming declaration status at the start of a project and re-confirming if the formula changes protects against this.
