The ingredient list

Flavors, defined by exclusion

Updated October 2026

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The definition So natural is the enumerated set It cross-references two lists Which matters commercially in this category And the allergen rule overrides the shorthand Which is the one that catches people Ask for the allergen status with the origin References

The definition is a list of permitted origins, and everything else.

The definition

Artificial flavor means any substance whose function is to impart flavor and which is not derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, fish, poultry, eggs, dairy products, or fermentation products thereof.

So natural is the enumerated set

The rule works by naming the origins that count as natural and treating the remainder as artificial. That is a question about the source of the substance rather than about how it was processed.

It cross-references two lists

Artificial flavor includes the substances listed in 21 CFR 172.515(b) and 182.60 except where they are derived from natural sources. So the same named substance can be natural or artificial depending on where it came from.

Which matters commercially in this category

A vanilla or a citrus note is a selling point, and "natural" is a word buyers weigh. Getting the classification right rests on supplier documentation about origin, not on the ingredient name.

And the allergen rule overrides the shorthand

A flavoring that bears or contains a major food allergen is subject to allergen labeling notwithstanding any other law. So "natural flavors" does not absorb a milk or soy component inside the flavor.

Which is the one that catches people

The whole appeal of a flavor declaration is that it is compact. The statute removes exactly that convenience where an allergen is involved, and that is a deliberate carve-out rather than an oversight.

Ask for the allergen status with the origin

One question to the flavor supplier covering both: where is it derived from, and does it bear or contain any of the nine major food allergens. The answer determines two separate parts of your label.

References

21 CFR 101.22(a), which defines artificial flavor by exclusion: a substance whose function is to impart flavor and which is not derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, fish, poultry, eggs, dairy products, or fermentation products thereof. law.cornell.edu

21 U.S.C. 343(w), the major food allergen labeling requirements. Paragraph (1) gives the two permitted forms, a "Contains" statement immediately after or adjacent to the ingredient list in type no smaller than that list, or the food source in parentheses after the ingredient name. Paragraph (4) applies the requirement to a flavoring, coloring or incidental additive notwithstanding any other law. law.cornell.edu

Written from federal statute and regulation, not from a kitchen. Food labeling has more parts than three sections, and a state cottage food program may add or subtract requirements for a local sale. Nothing here is clearance for a specific label, and whether an ingredient is cleared for food use is a question about that ingredient.