What Is Clean Label? A Buyer's Guide to the Claims and the Rules Behind Them

Clean label is a working term for food with a short list of ingredients that a shopper recognises. A 2021 review of clean label alternatives in meat products, published in Foods, states that food authorities had not yet defined the term, and that "food producers and consumers frequently use this terminology for food products with few and recognisable ingredients". This guide summarises selected rules from Singapore, EU and US texts and Codex guidance on the claims that carry the idea onto a pack, such as natural, no preservatives, free from, pure and organic. It also covers how a flavouring reaches your ingredient list, certifier marks and supplier questions.

Is Clean Label Legally Defined?

The 2021 Foods review on meat products states that there is "no official nor clear definition of the term". A 2025 review of clean label approaches in cheese production, also in Foods, says that "the absence of legislation in this field still renders its definition and characterization somewhat ambiguous and open to interpretation". A 2024 review of clean label alternatives for food preservation in Heliyon calls the definition vague and links the term to "being natural, simple, less processed, and free from unexpected allergens".

The Codex General Guidelines on Claims say that no food should be described or presented in a manner that is false, misleading or deceptive, and that the person marketing a food should be able to justify the claims made. Singapore's regulation 9(1) sets a binding rule of the same kind: it prohibits any claim or suggestion that is false, misleading or deceptive about matters including a food's nature, purity and composition, whether made by a statement, word, brand, picture or mark.

Which Clean Label Claims Do Regulators Govern?

Natural. The Codex guidelines say terms such as "natural", "pure" and "fresh" should follow the national practices of the country where the food is sold and stay consistent with the guidelines' list of prohibited claims. In the EU, Article 16 of Regulation (EC) No 1334/2008 sets conditions for describing a flavouring as natural: the flavouring component may comprise only flavouring preparations and/or natural flavouring substances, and "natural" may be combined with a named food, food category or flavouring source only if at least 95 per cent of the flavouring component by weight comes from that source. In the United States, FDA's page on the term, with content current as of 22 October 2018, says the agency "has not engaged in rulemaking to establish a formal definition for the term 'natural'" and describes a longstanding policy that nothing artificial or synthetic, including any colour additive, has been added to a food that would not normally be expected in it. Natural flavour itself is defined in 21 CFR 101.22(a)(3) by its source material, such as a spice, fruit or dairy product, with a significant function in food that is "flavoring rather than nutritional". Our article on what counts as a natural flavour compares the natural flavour definitions in EU, US and Singapore law with the Codex position.

No preservatives, no artificial flavours and other free-from claims. The Codex guidelines allow claims about absence if they are not misleading and the substance is not subject to specific requirements in a Codex standard or guideline, is "one which consumers would normally expect to find in the food", has not been replaced by another substance giving equivalent characteristics unless the nature of that substitution is clearly stated with equal prominence, and is permitted in the food. In the EU, Article 7(1)(c) of Regulation (EU) No 1169/2011 names, among the ways food information can mislead, suggesting that a food has special characteristics when all similar foods have them, "in particular by specifically emphasising the presence or absence of certain ingredients and/or nutrients". Unless regulation 9A or 9B permits it, Singapore's regulation 9(2) bars a label from implying that a food does not contain a food additive the Regulations do not permit, or a substance whose use in food is prohibited. The Singapore Food Agency's labelling guide gives this example of a prohibited claim: "Product Y does not contain partially hydrogenated oils and is safe for consumption", where partially hydrogenated oils are prohibited under the Food Regulations.

Pure. Regulation 9B(4) of Singapore's Food Regulations allows "pure", or any word of the same significance, only where the food is free from other added substances or is of the composition, strength and quality the Regulations require.

Organic. Regulation 9B(5) of Singapore's Food Regulations allows "organic", or any word of the same significance, only for food certified under an inspection and certification system that complies with section 6.3 of the Codex organic guidelines, GL 32-1999, or that substantially complies with those guidelines and is acceptable to the Director-General. The SFA guide adds that products labelled with organic claims must be accompanied by a certificate substantiating that certification. In the EU, Article 30(5)(a) of Regulation (EU) 2018/848 allows organic terms in a processed food's sales description only if the food meets the production rules the Article specifies and at least 95 per cent of its agricultural ingredients by weight are organic. For flavourings, the terms apply only to natural flavouring substances and preparations labelled under Article 16(2) to (4) of the flavourings regulation, with all flavouring components and their carriers organic. In the United States, 7 CFR 205.301 requires 100 per cent organically produced ingredients for "100 percent organic", at least 95 per cent for "organic", and at least 70 per cent for a multi-ingredient product labelled "made with organic (specified ingredients or food group(s))", each measured by weight or fluid volume excluding water and salt.

How Does a Flavouring Show Up on Your Ingredient List?

In the EU, Article 20 of Regulation 1169/2011 says the ingredient list need not include an additive whose presence is solely due to its being contained in an ingredient, in line with the carry-over principle of Regulation (EC) No 1333/2008, provided it serves no technological function in the finished product. Article 20 separately exempts carriers, and substances that are not additives but are used in the same way and for the same purpose as carriers, in the quantities strictly necessary. Article 18(3) of Regulation 1333/2008 covers the other case: an additive in a flavouring that has a technological function in your food is an additive of your food and must meet the conditions of use for your food. The SFA guide states a functional test for Singapore with effect from 30 January 2026: a carried-over additive present in an amount sufficient to perform a technological function in the finished product must be declared, and one present in an amount insufficient to perform such a function need not be. In the United States, 21 CFR 101.22(j) requires an added chemical preservative, unless exempt under 101.100, to be declared by its common or usual name together with a separate description of its function. Our guide to declaring a flavouring on a Singapore label covers the generic term, the natural, nature identical or artificial qualifier and how carried-over additives are treated.

What Do Certifier Marks Tell You?

Singapore's regulation 9(1) names brands and marks among the forms a false, misleading or deceptive claim can take. The SFA guide gives as an example of a misleading sign a logo indicating endorsement or approval by a food safety authority that suggests the product is safer than similar products without it. In the EU, Article 33(2) of Regulation 2018/848 describes the EU organic production logo as an official attestation, except when used in accordance with the second subparagraph of Article 33(1), and Article 33(5) allows national and private logos on products that comply with the regulation. In the United States, 7 CFR 205.311 limits the USDA seal to products described in 205.301(a), (b), (e)(1) and (e)(2), which include "100 percent organic" and "organic", and 205.304(c) bars the seal from packaged products in the "made with organic" tier. For packaged products labelled "100 percent organic" or "organic", 205.303(b)(2) requires the information panel to name the certifying agent that certified the handler of the finished product.

For a private mark, read what its owner says it covers, then check the claim printed beside it against the rules for that claim.

Is Clean Label a Safety Verdict?

Unless regulation 9A or 9B permits it, Singapore's regulation 9(2) also bars a label from implying that other food is unsafe, or that an ingredient the Regulations permit is unsafe. The Codex guidelines list claims that could give rise to doubt about the safety of similar food among those that should be prohibited. On 6 May 2026 a Member of Parliament asked whether the Healthier Choice Symbol or Nutri-Grade could include metrics such as artificial preservatives, colouring and flavours. The Ministry of Health 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 it would review the suggestions to consider possible refinements to its labelling schemes.

What Should You Ask a Flavour Supplier?

How will the flavouring be described on your label in each market, and with which qualifier? In the EU, Article 15 of Regulation 1334/2008 requires the packaging or containers of a flavouring not intended for sale to the final consumer to carry a sales description, either "flavouring" or a more specific name or description, and Article 16 sets the conditions for using "natural" in it.

Article 15 also requires a list, in descending order of weight, of the categories of flavourings present and the names of the other substances or materials in the product, or their E numbers where appropriate. That list may appear instead on consignment documents supplied with or before delivery, if "not for retail sale" appears on an easily visible part of the packaging or container. Ask which food additives are carried over from the flavouring and whether each performs a technological function in your finished product, then check its declaration under the carry-over rules above.

In the United States, 21 CFR 101.22(i)(4) requires a flavour supplier to certify in writing that any flavour it designates as containing no artificial flavour contains none, to the best of its knowledge and belief, and that it has added none; ask for that certificate when your US label relies on the designation. For a Singapore organic claim, ask for the certificate the SFA guide describes, and for the EU confirm that all flavouring components and their carriers are organic.

Our twelve questions to ask before you pick a flavour supplier in Asia cover the Singapore permitted solvent list, prohibited substances, allergen carry-over, SFA licensing and MUIS halal schemes. VKA holds halal certification from MUIS in Singapore and BPJPH in Indonesia. VKA's Singapore manufacturing site holds FSSC 22000 certification. To talk through the documents a clean label brief needs, contact our team.

Legal texts were read on 10 October 2026 in the versions listed in the sources. EU Regulations 1333/2008 and 2018/848 were read as originally published.

Is Clean Label a Regulated Claim?

The term itself has no fixed meaning in the reviews cited above: a 2021 review in Foods states there is no official definition, a 2025 review in Foods points to the absence of legislation, and a 2024 review in Heliyon calls the definition vague. The claims that make it up are regulated. Singapore's regulation 9(1) prohibits false, misleading or deceptive claims about matters including a food's nature, purity and composition, and regulation 9B sets conditions for "pure" and "organic". Article 7(1)(c) of EU Regulation 1169/2011 bars food information that misleads by suggesting a food has special characteristics that all similar foods share, in particular by emphasising the presence or absence of ingredients, and 7 CFR 205.301 sets the composition behind each US organic label.

What Does Clean Label Mean?

It is a working term for food with few, recognisable ingredients, which is how a 2021 review in Foods describes its use by producers and shoppers. A 2024 review in Heliyon links it to being natural, simple, less processed and free from unexpected allergens.

Is Natural Flavor Clean Label?

Whether a natural flavour fits a clean label brief depends on the brief, since the reviews above describe clean label as undefined or vaguely defined. The rules on natural flavouring are firmer. Article 16 of Regulation 1334/2008 sets conditions for describing a flavouring as natural, and 21 CFR 101.22(a)(3) defines natural flavor by its source material, with a significant function in food that is "flavoring rather than nutritional".

Can I Print "No Preservatives" on a Pack in Singapore?

The claim must not be false, misleading or deceptive under regulation 9(1) of the Food Regulations, and, unless regulation 9A or 9B permits it, regulation 9(2) bars implying that a food lacks an additive the Regulations do not permit. Check the ingredients you buy in as well as your own recipe: the SFA guide states that, with effect from 30 January 2026, an additive carried over from an ingredient must be declared when present in an amount sufficient to perform a technological function in the finished product, and its example is sorbic acid that still prevents spoilage.