Food Labels: What They Reveal and Conceal, Part 2

Food Labels

By Jennifer Handy

Labeling for unpackaged food

Most food labeling regulations apply to packaged food, but there are also labeling requirements and voluntary guidelines for unpackaged products. Foods sold in bulk bins, such as grains, flours, beans, and nuts, must have nutrition information available at point of sale - for example, listed on the container itself or on a card nearby. Since 2012, major cuts of raw, single-ingredient meat and poultry, as well as ground meat and poultry, are required by the U.S. Department of Agriculture (USDA) to have their nutrition information stated, with certain exceptions. Providing nutrition information for raw fruits, vegetables, and fish sold by the pound is voluntary, but the FDA urges food retailers to do so, and many major grocers comply.

Sometimes, the nutrition information is printed on posters or brochures, available in areas of the store where these products are displayed. This information is also available from the USDA National Nutrient Database website. However, consumers should be aware that fresh fruits and vegetables may contain additives (such as wax on apples or Citrus Red No. 2 on oranges) that are not listed at point of sale. To find out if a particular fresh fruit or vegetable has been coated with something, ask to see the shipping box for the item, which is required to display this information.

Organic and natural products

To be labeled USDA organic, a product must meet the requirements set forth by the USDA’s National Organic Program. The USDA defines an organic food as one that “has been produced through approved methods that integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” In practice, many organic farms and products fall short of this qualitative ideal, but this does not mean the organic label is meaningless. Organic products must meet several objective criteria. The most well-known is that organic crops must be grown without synthetic fertilizers, prohibited pesticides, or sewage sludge. In addition, they cannot be grown from genetically modified seed or irradiated to increase shelf life. While fresh fruits and vegetables (as well as grains, nuts, seeds, etc.) are simple to classify as either organic or not, products with multiple ingredients can be partially organic. These products can be labeled 100% organic if all ingredients (except for water and salt) are certified as such.

Organic products must be composed of at least 95 percent organic ingredients, as determined by weight, and products “made with organic ingredients” must be at least 70 percent organic. If a product has less than 70 percent organic ingredients, individual ingredients may be declared organic in the ingredient list, with the total percentage of organic ingredients stated on the information panel, near the nutrition information. Meat and poultry may be labeled organic if the animals were allowed access to pasture during the grazing season, were fed 100 percent organic feed, and were not given hormones or antibiotics.

The term natural may also be used for meat and poultry, but it has a very different meaning. USDA guidelines allow products to be labeled natural if they are minimally processed and contain no artificial ingredients, such as colors, flavors, or preservatives. Natural is a relatively low standard; feedlot cattle can qualify, as can chickens that never see daylight. Certified natural beef refers to beef endorsed by independent organizations (not the USDA) that set their own standards, which usually prevent the use of antibiotics but are much less stringent than organic standards.

USDA terms for poultry include free range and cage free, neither of which are high standards. Cage free means that the animals can move about in a room or building; it does not mean they have access to the outdoors. Free range means that they have access to the outdoors, but the outdoor area does not have to be large or even grassy. Pasture raised is the ideal standard for poultry (as well as meat), although use of this term is not regulated. Organic certification is not handled directly by the USDA, which instead accredits independent certifiers and periodically audits them.

While all certifiers must meet the same criteria in theory, not all represent the same level of quality. California Certified Organic Farmers (CCOF) and Oregon Tilth are examples of certifiers that have good reputations. Certifiers can be state agencies, non-profits, or for-profit corporations, and identifying the status of a certifier is a good first step in assessing it. Another strategy is to see which certifiers are used by honest companies that you know and trust. Some small growers and manufacturers produce foods that would meet organic standards - and may use the term organically grown on their labels - but choose not to get certified because they find the record-keeping requirements and the cost of the required annual audits too burdensome. Other growers opt out because they object to the system of organic certification on the grounds of ethics or sustainability. One such complaint is that organic farms are allowed to use chemical-laden feedlot manure on their fields, as discussed on the Chert Hollow Farm, LLC web site. Moreover, certain healthful foods, such as sea salt and wild salmon, cannot be certified organic because they are neither grown nor raised. Next week we'll discuss food ingredients lists.

This article excerpt was selected from the Fall 2014 Price-Pottenger Journal of Health and Healing.


  • Nutrition Labeling of Food, 21 C.F.R. Sect. 101.9 (2013). Food Safety and Inspection Service. Nutrition labeling of single-ingredient products and ground or chopped meat and poultry products. Fed Regist. 2010; 75:82148.
  • Nutrition Labeling of Raw Fruit, Vegetables, and Fish, 21 C.F.R. Sect. 101.42 (2013). U.S. Department of Agriculture. USDA National Nutrient Database for Standard References.   Updated December 7, 2011.
  • Food; Exemptions from Labeling, 21 C.F.R. Sect. 101.100 (2013). U.S. Department of Agriculture. National Organic Program. April 30, 2014.
  • Product Composition, 7 C.F.R. Sect. 205.301 (2013). Multi-Ingredient Packaged Products with Less Than 70 Percent Organically Produced Ingredients, 7 C.F.R. Sect. 205.305 (2013).
  • Livestock Feed, 7 C.F.R. Sect. 205.237 (2013).
  • Troxel TR. Natural and organic beef. University of Arkansas. FSA3013. Accessed May 23, 2014.
  • Chert Hollow Farm, LLC. Dropping organic certification. . March 12, 2004.

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