What Clean Label Means for the Flavour on Your Pack

Clean label has no legal definition in Australia, New Zealand, or in the EU, US or Singapore rules either. A 2021 review in the journal Foods states it plainly: "Food authorities have not yet provided a definition for the term “clean label”. However, food producers and consumers frequently use this terminology for food products with few and recognisable ingredients." What is defined is the thing a clean-label shopper actually reads, the statement of ingredients, which in Australia and New Zealand is built under Standard 1.2.4 of the Food Standards Code, where a flavouring is declared under s 1.2.4—7(4) as "flavouring" or "flavour" or by a more specific name.

What the 2026 Code Changes Did Not Touch

Nothing in the 2026 Code amendments changed how that list is built. Six amendments were gazetted in 2026, Nos. 247 to 252, and none of them touched Standard 1.2.4 and its statement-of-ingredients rules, Standard 1.2.3, Standard 1.3.1 or Schedule 16, which carries the food-additive class names and types; each of those instruments is still on a pre-2026 compilation. The one flavouring-relevant change was the reference edition of the FEMA GRAS list in Standard 1.1.2, which moved on 30 April 2026 to the lists published from 1960 to 2024, edition 31, under Amendment No. 249. The nutrition panel did not change either. FSANZ closed Proposal P1058 on 23 March 2026, ending the prospect of a separate added-sugars line, and stated that "There are no changes to existing nutrition labelling requirements as a result of the decision to close Proposal P1058." Clean-label positioning in Australia and New Zealand therefore still turns on the ingredient list, not on a new panel.

The Natural Colour Cautionary Tale

If you are planning a clean-label swap against a timetable, the natural-colour story of 2026 is the cautionary one. In the United States, a beetroot red listing and an expanded spirulina extract listing both carried early-2026 effective dates and both were stopped on 20 March 2026 after objections were filed, with the FDA recording that "The delay of the effective date is required by law following the filing of timely objections and a request for a hearing on the final order." Four further natural-colour petitions were filed between February and August 2026, and a filing is a docket opening rather than a permission. Orange B was revoked in the same window, effective 8 September 2026, but on abandonment rather than on safety: the FDA determined "that the authorized use of Orange B has been abandoned". None of this is Australian law, and none of the colours involved is permitted here. The transferable lesson is a formulation one, and the supplier side puts it plainly. Sensient's FY2025 Form 10-K notes that "much more natural color is generally needed to replicate the appearance of a synthetic color in an existing product", which is a dose, cost and label consequence a clean-label brief has to carry rather than discover.

Three Reviews, One Conclusion

The absence is not a gap waiting to close. The same 2021 review asks the question and answers it: "Over the last few years, food producers have identified the term “clean label” as an important market trend. Nevertheless, what does “clean label” mean? So far there, is no official nor clear definition of the term". Four years later a 2025 review in the same journal reported no movement, noting that "The absence of legislation in this field still renders its definition and characterization somewhat ambiguous and open to interpretation", and listing among the sector's live risks "regulatory challenges, such as the absence of standardized Clean Label definitions and compliance complexities". A 2024 review in Heliyon, from a different publisher, reaches the same place: "The term 'clean-label' has a vague definition. However, it can be related to concepts and ideas like being natural, simple, less processed, and free from unexpected allergens". All three independent reviews reach the same conclusion. State that there is no definition, then state the working definition you use.

What Shoppers Actually Select On

It is worth knowing what shoppers actually select on, because the received wisdom about short ingredient lists is weaker than the briefs assume. The 2025 IFIC Food and Health Survey, fielded in March 2025 with 3,000 United States adults, asked which criteria define a healthy food, allowing up to five choices. "Minimal or no processing" was chosen by 28 per cent, up 8 points since 2022; "Limited or no artificial ingredients or preservatives" by 25 per cent, up 7 points; and "Natural" by 24 per cent. "Limited number of ingredients" scored 14 per cent, up 5 points, the weakest of the clean-label cues measured. A separate question in the same survey found that "About four in ten Americans report looking for “natural” (41%) and “no hormones or steroids” (38%) label claims". The survey sampled United States adults and measures self-reported attention rather than purchases. The direction is clear enough: processing and named additives move people more than ingredient count does.

How the Ingredient List Is Built

The list a shopper inspects is governed by Standard 1.2.4, and flavour gets treated gently inside it. Section 1.2.4—7(4) provides that "If a *flavouring substance is an ingredient, it must be listed in the statement of ingredients by using: (a) the word 'flavouring' or 'flavour'; or (b) a more specific name or description of the flavouring substance", and s 1.2.4—3(2)(a) that "A statement of ingredients need not list: (a) an ingredient of a *flavouring substance". A flavour built from dozens of substances therefore occupies one short entry. The exemption covers the ingredients of the flavouring, not everything that arrives with it. A component carried in with a flavour that performs a technological function in your finished food is your additive to declare, which is the rule Article 18(3) of the European additives regulation states in terms and the reason the composition question belongs on the specification.

The Named Limits on the Single Flavour Line

The convenience has named limits, and they are the part that catches formulas late. Section 1.2.4—7(5) requires nine substances to be specifically declared where they are added as a flavouring substance or as an ingredient of one: L-glutamic acid, monosodium glutamate, monopotassium L-glutamate, calcium di-L-glutamate, monoammonium L-glutamate, magnesium di-L-glutamate, disodium guanylate, disodium inosinate and disodium-5′-ribonucleotides. Section 1.2.4—7(6) adds caffeine whenever it is added, whether as a flavouring substance or otherwise. If a savoury or umami-leaning system carries any of them, the clean single line does not survive.

The Allergen Line That Never Moves

The allergen line never moves for a marketing goal. Standard 1.2.3, s 1.2.3—4(5) makes the obligation bite where the allergenic food is present as "(b) a substance *used as a food additive, or an ingredient or component of such a substance; or (c) a substance *used as a processing aid, or an ingredient or component of such a substance." A flavouring is a substance used as a food additive, so a dairy, soy or wheat carrier inside it is declared on your label even though the flavouring's other ingredients need not be. The declaration is in Plain English Allergen Labelling form, with the required name in bold and a summary statement that under s 1.2.3—7(3) "must: (a) commence with the word 'Contains' and then list the *required name of each food to be declared; and (b) contain no other words." Both PEAL windows have closed, the transition on 25 February 2024 and the post-transition on 26 February 2026, so there is no older form to fall back on. A clean declaration is only clean if it is also complete.

What Travels In With the Flavour

What travels in with the flavour is the part a clean-label brief most often misses. Australian law expressly permits a defined set of carriers and preservation additives inside a flavouring. Schedule 15, s S15—3 provides that where a substance may be used as a food additive, "(a) the substance may be added in the form of a preparation of the substance; and (b) other substances may be used as food additives in the preparation in accordance with the permissions under category 0 of the table (preparations of food additives)." Category 0.3 of the Schedule 15 table then permits, among others, benzyl alcohol at 500 mg/kg in the final food, isopropyl alcohol at 1 000 mg/kg in the final food, butylated hydroxyanisole at 1 000 mg/kg, and ethanol, ethyl acetate, glycerol diacetate, glyceryl monoacetate and triethyl citrate at GMP. GMP is a ceiling rather than a licence: Schedule 15, s S15—4(1)(b) defines it as "a reference to 'GMP' is a reference to the maximum level necessary to achieve 1 or more technological purposes under conditions of GMP."

When a Carrier Becomes Your Additive

The European Union states the trap in that arrangement more explicitly than the Code does, and the logic is worth borrowing even where the law does not apply. Regulation (EC) No 1333/2008, Article 18(3) provides that "Where a food additive in a food flavouring, food additive or food enzyme is added to a food and has a technological function in that food, it shall be considered a food additive of that food and not a food additive of the added flavouring, food additive or food enzyme, and must then comply with the conditions of use for that food as provided for." In other words, a carrier or antioxidant that does a job in your product stops being the flavour house's additive and becomes yours, with your declaration and your limits. So ask your supplier which components of the flavour still do a job once it is in your food, not just what the flavour contains.

Clean Label Is Not Natural

Clean label also is not the same thing as natural, and the two get blurred in briefs to everybody's cost. The Food Standards Code does not define natural for a flavouring at all. The claim is governed by the Australian Consumer Law, where s 18(1) prohibits conduct that "is misleading or deceptive or is likely to mislead or deceive" and s 29(1)(a) prohibits a false or misleading representation "that goods are of a particular standard, quality, value, grade, composition, style or model". The ACCC's stated expectation is demanding: "The ACCC believes that consumers would have a reasonable expectation that a food describing itself to be natural or pure should not contain food additives or artificial preservatives." It classes "Natural" among standard, style and select claims rather than among its puffery examples. The United States position is different again and is sometimes misquoted as approval: the FDA states that "Although the FDA has not engaged in rulemaking to establish a formal definition for the term "natural," we do have a longstanding policy concerning the use of "natural" in human food labeling." A policy is not a definition, and no jurisdiction on this page offers one for clean label.

Flavour and the Percentage Declaration

One more thing the Code does not do is make a flavour trigger a percentage declaration, while a named or pictured ingredient does. The Note to s 1.2.10—2 reproduces s 1.1.2—4(2): "Despite subsection (1), any of the following is not a characterising ingredient: (a) an ingredient or category of ingredients that is used in small amounts to flavour the food;". So the flavour stays exempt from the percentage rule while the fruit on the front of the pack does not, which is a useful asymmetry when a clean-label brief is really a front-of-pack brief.

A Practical Checklist for a Clean-Label Brief

A clean-label flavour brief tends to run through the same checks. Decide first which dimension is wanted, because a shorter list, the removal of named additives and a defensible natural position pull in different directions and only one of them is usually the real requirement. Ask every flavour and compound-ingredient supplier for the full declaration of what is inside, including carriers, solvents, antioxidants and processing aids, not the single word flavour on a specification. Confirm the allergen status of each input, because that line is declared whatever else happens. Check which components perform a technological function in your finished food, because those become your additives with your declaration. Then read the resulting statement of ingredients in descending order of ingoing weight the way a shopper will, and confirm it says what you intend before the artwork is locked.

How VKA Australia Approaches Clean-Label Work

VKA® Australia develops and makes flavours in Southport, Queensland, and a clean-label brief is one we treat as a labelling problem as much as a flavour one. We work out how each option will read in the statement of ingredients, use masking and modulation to reduce the number of declarable additives a recipe needs, and keep the allergen and component breakdown of every flavour on file so the finished declaration holds up to inspection. Clean label has no legal definition, so the target is a declaration that satisfies the shoppers, retailers and markets you sell to. If you are working towards a cleaner ingredient list, talk to a flavourist directly and bring the current declaration so the label and the flavour can be rebuilt together. Our guide to flavour masking covers the technical side of taking an off-note, or an additive, out of a recipe, and our guides to natural flavours and FSANZ flavour labelling and natural claims cover the regulated ideas clean label borrows from.