Labeling 101: Characterizing Flavor

When the label, labeling or advertising of a food makes any direct or indirect representations about the primary recognizable flavor (e.g., word, vignette, imagery, etc.), that flavor would be considered a “characterizing flavor” and may require additional language on the primary display panel. 

A characterizing flavor is one that is emphasized through words, pictures, or implications on your product packaging, and the FDA has specific rules about how these must be labeled.

What Is a Characterizing Flavor?

A characterizing flavor is any flavor highlighted on your product that contributes to the consumer's impression of what the product will taste like. Examples include:

• A flavor mentioned in the product name ("Strawberry Yogurt")
• A flavor depicted in images on packaging (picture of cherries)
• Flavor claims ("Bursting with Blueberry Flavor!")

FDA Labeling Requirements

The FDA requires different labeling based on how the characterizing flavor is derived:

• If the product contains no artificial flavor simulating, resembling, or reinforcing the characterizing flavor, the name of the food on the PDP shall be accompanied by the common or usual name of the flavor. (21 CFR 101.22(i)(1))

• If the product contains natural flavor derived from the characterizing flavor and does not include an amount of characterizing ingredient to independently characterize the flavor, the name should include a qualifying statement (either “Flavored”, “Naturally Flavored”, or “Natural Flavor”). (21 CFR 101.22(i)(1)(i))
• If the product contains both a natural flavor and other natural flavor which simulates or reinforces the characterizing flavor, the name should include “naturally flavored with other natural flavor” or “natural flavor with other natural flavor” as a qualifying statement. (21 CFR 101.22(i)(1)(iii))

• If none of the flavor in the product is derived from the food whose flavor is simulated, the name should include “artificially flavored” or “artificial flavor” as a qualifying statement. (21 CFR 101.22(i)(1)(ii))

Flavor Prominence Requirements

The words "flavored," "with other natural flavors," or "artificially flavored" must appear in:

• Same typeface, size, style, and color as the characterizing flavor name
• Same prominence and conspicuousness
• Reasonable proximity to the name of the characterized flavor

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Common Compliance Issues

• Using pictures of fruits when the product contains only artificial flavors
• Highlighting a minor flavor component disproportionately
• Failing to label artificial flavors properly
• Not maintaining proper font size/style relationships between flavor name and qualifying terms

Understanding these regulations helps ensure your product labels meet FDA requirements and provide accurate information to consumers about what they're purchasing.