What Counts as a Natural Flavour Under the Food Standards Code

Nothing counts as a natural flavour under Australian law, because the Australia New Zealand Food Standards Code does not define "natural flavour" or "natural flavouring" anywhere. What it defines, in Standard 1.1.2, s 1.1.2—10, is a "flavouring substance", meaning "a substance that is used as a food additive to perform the technological purpose of a flavouring in accordance with this Code". The word natural on an Australian pack is therefore governed by the Australian Consumer Law, which prohibits misleading or deceptive conduct at s 18(1) and a false or misleading representation about a good's "composition" at s 29(1)(a).

Where the Code Is Silent

The phrase appears in none of the Code's definition or declaration instruments: Standards 1.1.1, 1.1.2, 1.2.3, 1.2.4, 1.2.10, 1.3.1, 1.4.1 and 3.2.2, and Schedules 7, 10, 15, 16, 19 and 24. The Code's own interpretation rule explains why nothing fills the gap. Standard 1.1.2, s 1.1.2—2(1) provides that "Subject to subsection (2), a term used in this Code that is also used in the *FSANZ Act has the same meaning as in the FSANZ Act, unless the contrary intention appears", and the definitions that do apply are a closed list in s 1.1.2—2(3). Natural is not in it, so the word keeps its ordinary meaning and is policed by general consumer law.

What the Code Defines Instead

What the Code does instead is sort flavourings by permission. Standard 1.1.2, s 1.1.2—10 defines a permitted flavouring substance to include "a substance that is listed in at least one of the following publications: (i) Generally Recognised as Safe (GRAS) lists of flavouring substances published by the Flavour and Extract Manufacturers' Association of the United States from 1960 to 2024 (edition 31);", with three further lists named in the same paragraph: "(ii) Chemically-defined flavouring substances, Council of Europe, November 2000; (iii) Annex I of Council Regulation (EU) No 872/2012 of 1 October 2012 adopting the list of flavouring substances [2012] OJ L267/1; (iv) 21 CFR § 172.515;". Alongside those listings sit two origin limbs, one covering a substance "obtained by physical, microbiological, enzymatic or chemical processes from material of vegetable or animal origin" and one covering a substance "obtained by synthetic means and which is identical to one of the substances described in paragraph (b)". Those limbs read like the natural and nature identical categories a supplier uses, but they are limbs of a permission test. A listing on FEMA's GRAS list is not an Australian approval on its own either: it still has to clear Schedule 16's quinine and caffeine exclusion, Schedule 15's food classes, the GMP ceiling and the Schedule 19 toxicant limits. That edition reference is itself only current since 2026. Amendment No. 249, instrument F2026L00481, repealed and substituted the subparagraph on 30 April 2026 so that the Code now names the lists published from 1960 to 2024, the thirty-first edition, in place of the earlier one. The permission therefore follows edition 31's contents, whichever way an individual entry moved between the two editions.

How a Flavouring Is Declared

On the label, the practical consequence is that all of it reads the same. Standard 1.2.4, s 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." The asterisk is the Code's marker for a defined term. Section 1.2.4—3(2)(a) then removes the need to open the flavouring up, since "A statement of ingredients need not list: (a) an ingredient of a *flavouring substance". That is why an Australian ingredient list can read sugar, water, citric acid, flavour even though the flavour itself is built from dozens of substances.

The Carve-Outs and the Allergen Line

Two carve-outs survive the exemption and they are not optional. Section 1.2.4—7(5) names nine substances that must be specifically declared when 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. Allergen labelling reaches further still. Standard 1.2.3, s 1.2.3—4(5) makes the obligation bite where an 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 whatever the flavour is called.

The Law That Governs the Word Natural

Because the Code is silent, the word natural is judged the way any other marketing claim is judged. The general prohibition is Australian Consumer Law s 18(1): "A person must not, in trade or commerce, engage in conduct that is misleading or deceptive or is likely to mislead or deceive." The specific one that catches a composition claim is s 29(1)(a), which prohibits a person from making "a false or misleading representation that goods are of a particular standard, quality, value, grade, composition, style or model or have had a particular history or particular previous use". Section 29 carries pecuniary penalties where s 18 does not, which is why the specific limb matters more to your regulatory team than the general one.

What the ACCC Says It Expects

The ACCC has said what it expects the word to mean on a food, and it is a higher bar than most briefs assume. Launching its food descriptors work, the ACCC stated that "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." In the accompanying presentation it classed "Natural" as a standard, style or select claim, defining that group as "those claims implying a relationship with a particular standard, style or product selection" and listing "'Pure', 'Fresh', 'Natural', 'Trim/Lean', 'Original', 'Genuine', 'True', 'Real'". Its puffery examples sat in a different group entirely, so treating natural as harmless marketing language is the wrong starting point. On organic, the neighbouring undefined term, the ACCC states the transferable principle: "All organic claims, whether they reference a standard or not, should be able to be proved".

The European Union: a Gate and 95 Per Cent

Comparing the position with the markets that do define the word is useful, provided the comparison never becomes the Australian rule. The European Union sets a gate and then a percentage. Regulation (EC) No 1334/2008, Article 16(2) provides that "The term ‘natural’ for the description of a flavouring may only be used if the flavouring component comprises only flavouring preparations and/or natural flavouring substances", and Article 16(4) allows the word to be combined with a named source "only be used in combination with a reference to a food, food category or a vegetable or animal flavouring source if the flavouring component has been obtained exclusively or by at least 95 % by w/w from the source material referred to." Note that Article 16 governs the sales description of the flavouring, not a claim on the finished food, which is the single most common misreading of it. The European list also moves on its own timetable, which is a useful reminder that authorised and natural are different axes. On 26 January 2026 Commission Regulation (EU) 2026/172 added a cooling substance, FL No 16.136, to the Union list after the European Food Safety Authority "concluded that such use under the proposed conditions of use does not raise a safety concern", and Commission Regulation (EU) 2026/175 added hesperetin dihydrochalcone, FL No. 16.137, the same day on the same footing. Both are authorisations of named substances in the European Union. Neither says anything about whether a substance is natural, and neither creates an Australian permission.

The United States: Derivation, and No Rule for the Claim

The United States defines natural flavor by derivation. Under 21 CFR 101.22(a)(3) it "means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional." That is a rule about an ingredient-list term, not about a front-of-pack claim. On the claim itself the FDA is explicit that no rule exists: "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." It adds that the policy "was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods", and that the agency "did not consider whether the term "natural" should describe any nutritional or other health benefit". The consultation that might have settled it closed on 10 May 2016 without a rule.

Codex as International Practice

Codex is the international reference, and it does define the natural end. CAC/GL 66-2008, cl 2.2.1.1 provides that "Natural flavouring substances are flavouring substances obtained by physical processes that may result in unavoidable but unintentional changes in the chemical structure of the components of the flavouring (e.g. distillation and solvent extraction), or by enzymatic or microbiological processes, from material of plant or animal origin." Its general principle at cl 3.3 is the one worth carrying into an Australian brief, since flavouring use is justified "provided that such use does not mislead the consumer about the nature or quality of food." Codex guidelines are not law in Australia or New Zealand, so cite them as international practice and never as the local requirement.

Evaluating a Natural-Flavour Claim

Build the claim on evidence for each component. Get a written statement from the flavour house of how each component qualifies as a permitted flavouring substance, naming the publication or the origin limb relied on. Get the source material and the process for every component you intend to describe as natural, and get the carriers, solvents and processing aids named too, because they are part of what arrives in your food. Check that the product name, the front-of-pack copy and the imagery together do not suggest an origin or composition the flavour does not have, since s 18 and s 29 are assessed on the overall impression rather than a single sentence. If the product also sells into the European Union or the United States, hold the Article 16 position and the 21 CFR 101.22(a)(3) position separately, because neither settles anything in Australia. Then keep all of it in one folder against the SKU.

How VKA Australia Approaches Natural Flavours

VKA® Australia is an Australian flavour house. We develop and blend flavours in Southport, Queensland, with an Australian team, across fruit, confectionery, brown and dairy directions. You can browse the flavour range or explore food flavouring by type, from banana to bubblegum. Our Essences Portfolio covers the vanilla and true-to-nature directions where the natural question comes up most often. We match your brief to the matrix and processing your product will see, so the profile holds through manufacture and shelf life rather than only at the bench. If you are working on a natural-flavour project for the Australian or New Zealand market, talk to our flavourists about a natural flavour project.