Welcome to the first Regulatory Arena of 2015: the Year of the Clean Label! The clean label has been identified as one of the key trends of 2015, and in recognition of the importance of the clean label to Canadian consumers and industry, we will be devoting all four 2015 editions of the Regulatory Arena to the clean label.
In this first instalment of our four-part series, we will define the “clean label” and set the stage for the upcoming discussions. Our Spring/Summer edition will look at the treatment of the clean label in Canada as compared to the United States. In our Fall edition, we will dig into some “hot topics” in clean labeling: GMO-free, all natural, and the ingredients that Canadian consumers want to see the most (and the least) of. Finally, in the Winter edition, we will look more closely at the risks to industry linked to the clean label, particularly around compliance and enforcement by the CFIA. Of course, throughout the year we will also keep you posted on the latest developments in Health Canada’s modernization makeover, particularly as it relates to labelling.
The seemingly enormous market demand for clean labels in a number of global regions shows no sign of abating. The questions for industry: what is a “clean label” and should I (and if so, how can I) capitalize on the trend. But first, what is a clean label?
Defining “Clean” Label”
The concept of clean labeling has been gradually building over the last few decades. So-called clean labels were essentially non-existent prior the early 2000s but since then, clean-label product launches have been growing steadily to a rate of more than 4,000 a year. The movement is a global phenomenon, with enormous popularity in Europe and increasing popularity in North America and Asia.
As with many trends in the food industry, this one is very much consumer-driven. However, despite all the hype that the clean label is getting, there is no real consensus on what a clean label is, with the term still meaning different things to different people. Over here in the Regulatory Arena, we see two primary elements to the clean label trend: the push toward increased transparency in labeling, and the use of ingredients with perceived benefits.
As we have discussed in a number of past columns, the push for increased transparency is a hot topic in general, and is a key driver of Health Canada’s modernization makeover. Health Canada defines transparency as “making relevant, timely and useful information available to the public in easy to access formats” in order to “strengthen [Canadians’] trust in [Health Canada’s] regulatory decisions” and help “Canadians take action on their health and safety.”
Similar themes apply to the demand for clean labels: those pushing industry for clean labels are essentially asking for more accessible information about what is in food, in order for them to make informed choices for themselves and their families.
In order to make food labels more understandable (i.e. transparent), industry is being driven to avoid extensive ingredient lists full of chemicals, and other hard-to-pronounce ingredients. The clean label consumer is put off by extensive ingredient lists full of foods she/he doesn’t recognize and can’t pronounce. There is a perception that the shorter the ingredient list, the less there is to hide.
The second element of the clean label trend is tied to the perceived benefits of certain types of ingredients. In addition to wanting short, clean ingredients lists, clean label advocates want industry to use certain types of ingredients. In this way, the clean label trend is linked to other hot food trends, like the push toward GMO-free, organic and all natural ingredients.
According to the 2013 Gallup Study of Clean Food & Beverage Labels, today’s clean label consumers are particularly interested in products that are “all natural,” contain recognizable ingredients, with no artificial ingredients, no added sugar, no high fructose corn syrup, and no MSG.
The Impact on Industry
As with many food trends, the push for clean labels is pressuring many in industry to reformulate and repackage in order to meet consumer demands. Seemingly offensive additives and ingredients are being removed and “clean” ingredients are being sourced. Manufacturing facilities are also becoming “clean” as dedicated organic, allergen-free and non-GMO lines are introduced. Labels are being rewritten in plain, simple language.
In some cases, the clean label trend can be a great benefit to manufacturers as simplified ingredients can reduce operating costs with fewer raw material SKUs and result in export-friendly foods and formulas. However, others in industry are approaching the clean label trend with a little more caution. It is no secret that the cost of following food trends can be substantial, with little or no guarantee of how long the trend will last.
The clean label trend speaks volumes to the higher standard to which consumers are now holding industry. Today’s consumer is more educated and is making more informed decisions about the food they buy, and they are demanding that industry provide them with the tools needed to make informed decisions. Regardless of your views on food trends in general, it is difficult to imagine the Canadian consumer becoming less interested in what is in his/her food anytime in the near future. And so at a minimum, the next three instalments of the Regulatory Arena will focus on how industry can provide Canadians with this much sought-after information in the context of the clean label.