Types of flavourings and organic regulations

Introduction: what is a flavouring?

Flavourings are defined by Regulation (EC) No. 1334/2008 as products:

• not intended to be consumed as such, which are added to food in order to impart or modify odour and/or taste;
• made or consisting of the following categories: flavouring substances, flavouring preparations, thermal process flavourings, smoke flavourings, flavour precursors or other flavourings or mixtures thereof.

A flavouring can be characterised as follows:

• its flavouring part, which comprises exclusively components from the above-mentioned categories and regulated by Regulation (EC) No. 1334/2008;
• its non-flavouring part, which serves as a carrier and comprises components that are additives, regulated by Regulation (EC) No 1333/2008.

Flavour Manager's databases include all these components and their limitations, allowing you to verify that you're formulating or using your flavours in compliance with the various regulations.

The different types of flavourings

Depending on their composition, flavourings may be labelled with different designations, as detailed below.

Please note that the use of these designations does not exempt you from certain additional mandatory labelling requirements. Flavour Manager's regulatory check module allows you to find out what labelling requirements apply to the flavouring, if any.

Flavouring, X flavouring

This designation covers all flavourings and can be used for any flavouring regardless of its composition.

Natural flavouring

Regulation (EC) No. 1334/2008 states that the designation "natural flavouring" may be used if the flavouring component of the flavouring comprises only flavouring preparations and/or natural flavouring substances.

This designation may only be used if the flavouring component is derived from different source materials and where a reference to the source materials would not reflect their flavour or taste.

The non-flavouring part of the flavouring is not taken into account in this definition.

Natural X flavouring

X is a food, a food category or a vegetable or animal flavouring source.

Regulation (EC) No. 1334/2008 states that the designation "natural X flavouring" may be used if the flavouring component of the natural flavouring has been obtained exclusively or by at least 95 % by weight/weight from the source material X referred to.

The flavouring part not derived from the source material (maximum 5%) must not imitate this source, and is only used for standardisation purposes or to provide other aromatic typicity.

The flavour or taste of the source material X referred to must be recongnisable in the final product.

The non-flavouring part of the flavouring is not taken into account in this definition.

The natural X flavouring is sometimes called "95/5 flavouring".

Natural X flavouring with other natural flavourings

X is a food, a food category or a vegetable or animal flavouring source.

Regulation (EC) No. 1334/2008 states that the designation "natural X flavouring" may be used if the flavouring component of the flavouring is partially (and less than 95% weight/weight) derived from the source material X referred to.

The flavour or taste of the source material X referred to must be recongnisable in the final product.

The non-flavouring part of the flavouring is not taken into account in this definition.

The natural X flavouring with other natural flavourings is sometimes called "WONF flavouring".

Specific name

The specific name of a material can be used if the flavouring is 100% composed of that material. This is the case for extracts and essential oils. For example: "vanilla extract", "lemon essential oil", etc.

This flavouring is sometimes called "FTNS" (From The Named Source).

Flavourings status with respect to organic regulations

Since January 1st, 2022, organic-labelled products using flavourings are subject to stricter policies given by new Regulation (EC) No. 2018/848.

In concrete terms, new organic food and beverage products can only include "natural X flavourings" (see above). Besides, the flavourings that are used must be organic or organic-suitable. The quantity of organic flavourings is counted among the 95% minimum organic part of the final product. The quantity of organic-suitable flavourings is counted among the 5% maximum non-organic part of the final product.

Flavour Manager allows you to classify your flavours according to their organic, organic-suitable or non-organic status, as defined below.

Organic flavouring

The organic flavouring is a natural flavouring of X composed of a minimum of 95% organic ingredients and whose composition respects the requirements of Regulation (EC) No. 2018/848.

Organic-suitable flavouring

The organic-suitable flavouring is a natural flavouring of X. It is not organic but can be used in the composition of an organic product as defined in Regulation (EC) No. 2018/848.

In particular, it must not contain GMOs or ingredients that have undergone ionising treatments.

Non-organic flavouring

The non-organic flavouring may not be used in the composition of an organic product as defined in Regulation (EC) No. 2018/848.