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Getting started

Garlic is not a spice

By Dwight Davis, Founder

Updated

On this page14
"except for those substances which have been traditionally regarded as foods, such as onions, garlic and celery."

The exception is explicit

The definition excludes substances traditionally regarded as foods, and it names onions, garlic and celery as the examples.

So garlic powder is not a spice under this definition

Which surprises almost everybody, and the reason is not botanical. It is that garlic has traditionally been regarded as a food.

And the same goes for onion powder and celery seed

All three named, all three excluded, and all three sitting in the spice rack of every kitchen in the country.

The list is introduced as examples

Such as onions, garlic and celery. So other substances traditionally regarded as foods are excluded too, and the definition does not enumerate them.

Which means the category has a soft edge

Traditionally regarded as a food is a judgment about custom, not a test with a threshold.

The consequence is a labeling one

A product that is not a spice cannot be declared as spice, and has to be declared by its own name instead.

Which is why ingredient lists say onion powder

Rather than folding it into spice. The exception is doing visible work on labels people read every day.

And none of it changes the container

Garlic powder has the same volatile oil problem, the same clumping problem and the same light problem as anything else on this shelf.

So the container questions are uniform across the group

Which is unusual. Most properties here find different physics for different leaves and this one finds one physics and several labels.

The third condition is about function

Whose significant function in food is seasoning rather than nutritional. Which excludes something added in quantity for its nutrition.

And the fourth is true to name

Three words doing a great deal of work: the substance has to actually be what it is called.

And the exception is about custom, which moves

Traditionally regarded as a food is a statement about how a thing has been treated over time. It is the only clause in the definition with no fixed test behind it.

Four conditions and an exception, in one sentence

Which is why the sentence is quoted in full on these pages rather than summarized.

References

21 CFR 101.22(a)(2): "The term spice means any aromatic vegetable substance in the whole, broken, or ground form, except for those substances which have been traditionally regarded as foods, such as onions, garlic and celery; whose significant function in food is seasoning rather than nutritional; that is true to name; and from which no portion of any volatile oil or other flavoring principle has been removed." The same paragraph provides that "paprika, turmeric, and saffron or other spices which are also colors, shall be declared as 'spice and coloring' unless declared by their common or usual name", and cross-refers to the spice lists in 21 CFR 182.10 and part 184, which are not enumerated here. The definition addresses a spice from which volatile oil has been removed and is not a shelf-life rule. law.cornell.edu
Written from 21 CFR 101.22(a)(2) and from the catalog as it stood on 19 October 2026. That definition is aimed at a spice from which volatile oil has been removed deliberately and is not a shelf-life rule; nothing here says how long any spice keeps or whether any product has lost volatile oil. The spice lists in 21 CFR 182.10 and part 184 are cross-referred in the section and are not enumerated here. There is no one-way degassing valve anywhere in this catalog.