Clean Label Flavours, and What They Mean for Your Ingredient List

“Clean label” has no legal definition in any market. A 2021 review in 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 flavouring itself, and a clean-label reformulation usually does not change the number of lines on your ingredient list, only what those lines say and which of the things travelling inside the flavour have to surface on your pack.

Four Years of Literature, No Definition

The absence of a definition is not a gap that has quietly closed. The same 2021 review in Foods 10(7):1615 puts it as a 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” A 2025 review in Foods 14(5):805 finds the position unchanged and identifies the cause as legislative: “The absence of legislation in this field still renders its definition and characterization somewhat ambiguous and open to interpretation” Heliyon 10(16):e35815 confirms it outside that journal: “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”

What 'Natural' Does Define, and Where

“Natural” is firmer, but only in narrow places and only about the flavouring. In the EU, Article 16(2) of Regulation (EC) No 1334/2008 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) adds the source rule: “The term ‘natural’ may 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. The description shall read ‘natural “food(s) or food category or source(s)” flavouring’.” In the United States there is no such rule. FDA's own page says so: “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. The FDA has considered the term "natural" to mean that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food.” And the Australia New Zealand Food Standards Code defines “natural” for a flavouring nowhere at all, which means a natural claim there answers to general misleading-conduct law rather than to the Code.

Your Ingredient List Usually Reads the Same

Now the part that decides whether a reformulation is worth it. In the EU a flavouring is designated by “‘flavouring(s)’ or by a more specific name or description of the flavouring if the flavouring component contains flavourings as defined in points (b), (c), (d), (e), (f), (g) and (h) of Article 3(2) of Regulation (EC) No 1334/2008” In the United States, 21 CFR 101.22(h)(1) permits that “Spice, natural flavor, and artificial flavor may be declared as “spice”, “natural flavor”, or “artificial flavor”, or any combination thereof, as the case may be.” In Australia and New Zealand, section 7(4) of Standard 1.2.4 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.” In Singapore, First Schedule item 11 permits the generic term flavour or flavouring, qualified by the words natural, nature identical or artificial where one of them applies, and the item is quoted in full in our guide to Singapore flavour labelling. In all four, a flavour built from dozens of components collapses to a single line, so swapping artificial for natural changes the adjective and not the line count.

What Travels Inside a Flavouring

What can change the line count is what travels inside the flavouring. Codex names the category: “Non-flavouring food ingredients are food ingredients, such as food additives and foodstuffs that can be added to flavourings and are necessary for dissolving, dispersing, or diluting flavourings, or are necessary for the production, storage, handling and use of flavourings.” Singapore closes the solvent list outright in regulation 22(2), which names twelve permitted solvents and nothing else, propylene glycol, triacetin and ethyl alcohol among them; the clause is quoted in full in our guide to choosing a flavour supplier in Asia. The EU permits the classic liquid-flavour carriers and caps them in the finished food, at “3 000 mg/kg from all sources in foodstuffs as consumed or as reconstituted according to the instructions of the manufacturer; individually or in combination. In the case of beverages, with the exception of cream liqueurs, the maximum level of E 1520 shall be 1 000 mg/l from all sources” It also permits antioxidants inside a flavouring, with a separate ceiling for essential oils: “1 000 mg/kg (propyl gallate, TBHQ and BHA, individually or in combination) in the essential oils” None of that is unusual. It is simply present, and whether it reaches your label is a separate question.

The Carry-Over Test Is Functional

That question is answered by a functional test, not by a disclosure rule. Under Article 20(b)(i) of Regulation (EU) No 1169/2011 the ingredient list need not include “food additives and food enzymes: (i) whose presence in a given food is solely due to the fact that they were contained in one or more ingredients of that food, in accordance with the carry-over principle referred to in points (a) and (b) of Article 18(1) of Regulation (EC) No 1333/2008, provided that they serve no technological function in the finished product” Article 20(c) exempts “carriers and substances which are not food additives but are used in the same way and with the same purpose as carriers, and which are used in the quantities strictly necessary” The carry-over principle those provisions point at sits in Article 18(1)(b) of Regulation 1333/2008, which covers an additive that “in a food to which a food additive, food enzyme or food flavouring has been added, where the food additive: (i) is permitted in the food additive, food enzyme or food flavouring in accordance with this Regulation; and (ii) has been carried over to the food via the food additive, food enzyme or food flavouring; and (iii) has no technological function in the final food”

When a Carried-Over Additive Becomes Yours

Article 18(3) then reverses the outcome. Article 18(3) of Regulation 1333/2008 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.” If the antioxidant that came in with your flavour is still protecting your product, it is now your additive, declared by category and name or number, and subject to the conditions of use for your food category. Singapore applies the same test in regulation 5(4)(b)(vi): “(A) where the food additive is in an amount sufficient to perform a technological function in that product, the food additive must be specified by its appropriate designation; and (B) to avoid doubt, where the food additive is in an amount that is not sufficient to perform any technological function in that product, the food additive need not be specified” That is where the clean-label risk in a formulation usually sits, rather than in the flavour itself. The natural against artificial distinction underneath the qualifier is covered in what counts as a natural flavour.

What Can Never Hide Behind 'Flavouring'

A short list of things can never hide behind the word at all. In the EU, Annex VII Part D point 3 of Regulation 1169/2011 requires that “Quinine and/or caffeine used as a flavouring in the production or preparation of a food shall be mentioned by name in the list of ingredients immediately after the term ‘flavouring(s)’.” In the United States, 21 CFR 101.22(h)(4) requires that “Any salt (sodium chloride) used as an ingredient in food shall be declared by its common or usual name “salt.””, the same applies to monosodium glutamate under (h)(5), and (h)(7) provides that “no protein hydrolysate used in food for its effects on flavor may be declared simply as “flavor,” “natural flavor,” or “flavoring.”” In Australia and New Zealand, Standard section 7(5) of Standard 1.2.4 requires that “If any of the following substances are added to a food for sale as a *flavouring substance or as an ingredient of a flavouring substance, the name of the substance must be specifically declared”, naming nine glutamate and ribonucleotide substances, and section 7(6) of the same Standard adds that “If caffeine is added to a food for sale (whether as a *flavouring substance or otherwise), it must be listed in the statement of ingredients as caffeine.” Telling a customer that everything declares as flavouring is wrong the moment a system carries any of these.

The One Drop-Off the US Allows

The United States does allow a genuine drop-off, on the same functional logic. 21 CFR 101.22(h)(2) provides that “An incidental additive in a food, originating in a spice or flavor used in the manufacture of the food, need not be declared in the statement of ingredients if it meets the requirements of § 101.100(a)(3)”, and that cross-referenced provision covers incidental additives present at insignificant levels with no technical or functional effect in the food.

What Your Supplier Must Put in Writing

Your supplier is the source of every input to those tests, and in the EU the specification is prescribed. Article 15(1) of Regulation 1334/2008 requires “(a) the sales description: either the word ‘flavouring’ or a more specific name or description of the flavouring”, and separately a list, in descending order of weight, of the categories of flavourings present and the names or E numbers of every other substance in the product. In the United States the obligation is a certificate: “A flavor supplier shall certify, in writing, that any flavor he supplies which is designated as containing no artificial flavor does not, to the best of his knowledge and belief, contain any artificial flavor, and that he has added no artificial flavor to it.” A clean-label brief that does not request both is a brief that cannot be verified.

Two Things Clean Label Is Not

Two things clean label is not. It is not a safety verdict: none of the instruments above treats a natural flavouring as safer than a synthetic one, and Codex frames the whole question as honesty rather than health, requiring that “The use of flavourings is justified only where they impart or modify flavour to food, provided that such use does not mislead the consumer about the nature or quality of food.” It is also not a costed decision anyone can put a number on publicly. Figures circulate for what natural flavours cost relative to synthetic ones and for the share of launches carrying a clean-label claim, but they come from suppliers and market-research vendors without a published method. Ask your own supplier for your own numbers.

What Singapore Said in May 2026

Singapore said something on this in 2026 that is worth having to hand. On 6 May 2026 Parliament asked MOH to add artificial preservatives, colouring and flavours to the Healthier Choice Symbol or to Nutri-Grade. MOH replied that “Food additives, such as preservatives, colourings and flavourings are separately regulated by the Singapore Food Agency (SFA) for food safety purposes” and that “We will review the suggestions to consider possible refinements to our labelling schemes.” Two readings follow. No artificial flavour is not a Singapore labelling category and there is no scheme that grades it, so it is a marketing claim standing on the general prohibition against misleading a consumer, not on a front-of-pack framework. And MOH has not ruled a future change out, so a brand building a whole position on the absence of one is exposed to a review that has been left open.

Natural Colours: A Cautionary Story

The natural-colour story of 2026 is the clean-label story of 2026, and it is a cautionary one rather than a green light. In the United States, beetroot red and spirulina extract were both listed as exempt colour additives by orders published on 6 February 2026, and both orders were then “delayed indefinitely” in March 2026 after objections and a hearing request were filed. FDA is explicit that the delay is procedural rather than a change of view on safety, but the practical position for a formulator is the same either way: neither is available. Four more natural-colour petitions were merely filed in 2026, including safflower extract on 20 July and a gardenia blue expansion on 4 August, and a filing is a docket opening. Gardenia blue's existing US listing covers six named categories, not colours generally. None of these is permitted in Australia or New Zealand, where none appears on the FSANZ work plan. And the substitution is not like for like: Sensient's own 2025 annual report states that “much more natural color is generally needed to replicate the appearance of a synthetic color in an existing product”. A natural alternative existing is not the same as it being approved, available or stable at your dose.

Abandonment, Not Only Prohibition

The synthetic estate is shrinking by disuse as much as by prohibition, which is a more accurate framing than a ban narrative. FDA revoked the listing for Orange B on 23 July 2026 on the ground that “the authorized use of Orange B has been abandoned” and that the regulation was outdated, effective 8 September 2026, and it has proposed the same treatment for Citrus Red No. 2 on the basis that it has not been certified for food use in the United States since 2020. FD&C Red No. 3 is the one genuine safety revocation, and it is not in force yet: FDA lifted the administrative stay on 5 August 2026 and confirmed the dates, 15 January 2027 for food and dietary supplements and 18 January 2028 for ingested drugs. Saying Red 3 is banned without the 2027 date is wrong today.

What Shoppers Say, and Where They Were Asked

On what shoppers mean by any of this, one 2026 survey is quotable with its limits attached. The International Food Information Council's 2026 Food and Health Survey, fielded 22 March to 8 April 2026 among 3,005 United States adults weighted to the American population, found natural named by 28 per cent as a definition of a healthy food and limited or no artificial ingredients or preservatives by 27 per cent, up 10 points since 2022, with familiarity with the term ultraprocessed food at 52 per cent against 32 per cent two years earlier. It is a United States sample with a first Canadian addition and no Asian or Australasian respondents, so it evidences a direction of travel in one market and nothing about a Singapore shopper. No peer-reviewed 2025 or 2026 measurement of trust in natural claims among South-East Asian consumers was obtainable at all.

Flavourings Are Counted as a UPF Input

The counterpoint a clean-label brief should be ready for is that flavourings are not treated as neutral in the ultra-processed food debate. A March 2026 analysis of New Zealand import data over thirty years codes flavourings into the NOVA group 4 category as “food-derivatives/additives”, and reports that this subgroup's per-capita import volume has grown faster than any other ultra-processed subgroup since 2011. Nothing about a clean label changes that classification. It is better to know the argument than to be surprised by it in a presentation.

Turning the Aspiration Into a Specification

Four questions turn the aspiration into a specification a flavour house can quote against. How will each flavour be designated on the finished label in each destination market, and with which qualifier. Which carriers, solvents and additives are in it, at what level, and does each perform a technological function in your product rather than only in the flavouring. Does anything fall into the categories that must be declared regardless, such as quinine, caffeine, glutamates, ribonucleotides or a protein hydrolysate. What is the allergen position, including carry-over.

How VKA Approaches Clean Label

At VKA we develop natural and clean-label flavours for the Singapore and wider ASEAN market, and we treat the declaration as part of what we deliver rather than a detail to settle later. For each flavour we set out how it should be declared on your finished label, the carriers and any additives it contains with their E or INS numbers and whether they carry a technological function into your product, its allergen status, and its halal and FSSC 22000 documentation where you need it. Because the cleanest label is designed in from the first sample rather than retrofitted, we build the natural and free-from constraints into the brief alongside the taste, the process and how long the flavour lasts, and where removing an additive lets an off-note surface, that becomes a job for flavour masking. To see the natural profiles we work from, browse our Essences Portfolio and Culinary Portfolio, read how a flavouring is declared on a Singapore label, or talk to a flavourist directly about a clean-label brief and the markets it has to clear.