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Stevia and stevia-derived ingredients can be labeled as natural flavors in many countries around the world, but only within certain limits on use levels specified by international guidelines. There are many reasons manufacturers using stevia may want to declare it as a “natural flavor” on their label. This may include brands or flavor companies that are reformulating and adding stevia, but would prefer to avoid changing their existing product label. While consumer favorability of stevia continues to significantly improve, some manufacturers may still prefer to avoid listing stevia as an ingredient on their labels. Increasing regulation and policies around product labeling can be a factor as well. Some countries like Mexico have recently implemented a warning label for children to indicate when a product contains sweeteners. In these cases, applying stevia as a natural flavor for a small boost of sweetness allows manufacturers to avoid the warning label on their products.
Natural Flavor Labeling Guidelines from FEMA
The Flavor & Extract Manufacturers Association (FEMA) is an industry organization that works with government legislators and regulators, and the association creates and issues labeling guidelines for flavors. Its guidelines are widely followed by many countries around the globe, including the US. For its guidelines around stevia as a natural flavor, the FEMA panel reviews data that validates whether the flavor on its own tastes sweet or not at low levels.
FEMA maintains and catalogs a vast library of Generally Recognized as Safe (GRAS) ingredients. Many pure stevia extracts have a FEMA number in its library of flavor ingredients. The table below lists these stevia types, along with the corresponding FEMA number and an example of usage level in common applications. Please review the FEMA number on their website for specific application limits.
|Stevia Ingredient||FEMA Number and Guideline to Label as a Natural Flavor|
|Reb A 60||FEMA 4771, Most applications < 30ppm, Gum < 200ppm|
|Reb A 80||FEMA 4772, Most applications < 35ppm, Gum < 234ppm|
|Reb A||FEMA 4601, Most applications < 30ppm, Milk < 45ppm, Cereal < 50ppm, Gum <200ppm, Meat < 75 ppm|
|Reb C||FEMA 4720, Non-alcoholic beverages < 250ppm, Cereal < 400ppm, Gum < 0.1%, Jam < 300ppm|
|Reb D 95||FEMA 4921, Most applications < 32.5ppm, Gum < 325ppm|
|Reb E 85||FEMA 4936, Most applications < 45ppm|
|Reb M 80/85||FEMA 4895/4957, Several applications < 20ppm|
|Reb M 90||FEMA 4968, Most applications < 35ppm, Baked < 70ppm, Cereal < 100ppm, Milk products < 45ppm|
|Reb M 95||FEMA 4922, Most applications < 24ppm, Gum < 240ppm|
|Stevioside||FEMA 4763, Beverages < 35ppm, Baked and Candy < 65ppm, Sauces and snacks < 30ppm, Milk products < 55ppm, Gelatins and Puddings < 65ppm|
|Stevioside 70||FEMA 4911, Most applications < 50ppm, Baked < 200ppm, Cereal < 250ppm|
|Reb B 95||FEMA 4978, Most applications < 30ppm|
Enzyme-Modified Stevia (Glucosylated Steviol Glycosides)
Stevia can sometimes be processed with an enzyme to improve a formulation’s taste profile, slightly increase upfront sweetness, and provide taste-masking — or even a slight mouth-feel — to a product. This type of stevia is called Glucosylated Steviol Glycosides (GSG), or enzyme-modified stevia. There are multiple FEMA numbers for this type of stevia product, the most common one being FEMA 4728. Please see the tables below for a current list and specific application limits.
Natural Flavor Usage Limits by GSG Stevia Product Type
|FEMA Number||GSG Stevia Product Type||Usage Limits as Natural Flavor|
|FEMA 4728||Glucosylated steviol glycosides||See chart below|
|FEMA 4845||Glucosylated stevia extract||Most applications < 100ppm|
|FEMA 4876||Enzyme-modified stevia, stevioside 20%||See chart below|
|FEMA 4909||Glucosylated steviol glycosides, 70-80%||See chart below|
|FEMA 4910||Glucosylated steviol glycosides, 40%||Most applications < 135ppm|
|FEMA 4931||Glucosylated steviol glycosides, 90%||Most applications < 100ppm|
|FEMA 4947||Glucosylated stevia extract 40% with 14% Rebaudioside A||Most applications < 60ppm|
|FEMA 4950||Stevia rebaudiana extract with Rebaudiosides A and M||Most applications < 50ppm|
|FEMA 4951||Glucosylated steviol glycosides 90% supraglucosylated rebaudioside A||Most applications < 70ppm|
|FEMA 4952||Glucosylated steviol glycosides 91% supraglucosylated rebaudioside D||Most applications < 50ppm|
|FEMA 4953||Glucosylated steviol glycosides 58% supraglucosylated stevioside||Most applications < 100ppm|
|FEMA 4992||Rubusosides enriched glucosylated steviol glycosides||Most applications < 170ppm|
Natural Flavor Usage Limits (ppm) by GSG Stevia and by Product Application
|GSG FEMA Number||4728||4845||4876||4909||4910||4931||4947|
|Condiments and Relishes||200||100||110||—||135||100||—|
|Confections and Frostings||100||100||110||—||135||100||60|
|Fats and Oils||189||—||110||—||135||100||60|
|Gelatins and Puddings||133||100||110||—||135||100||60|
|Instant Coffee and Tea||175||100||100||65||135||100||60|
|Jams and Jellies||200||100||110||—||135||100||60|
|Seasonings and Flavors||175||100||100||—||135||100||60|
For more in-depth information on usage and labeling of Glucosylated Steviol Glycosides in different product applications, view our webinar presentation on GSGs from the 2020 Clean label Conference.
Important Considerations for Natural Flavor Labeling of Stevia
As already described, stevia can be labeled as a natural flavor in a vast variety of product applications. However, one application where this isn’t the case is tabletop sweeteners. For such products as well as other sugar substitute applications (i.e. baking blend sold in a stand-up pouch), natural flavor labeling for stevia is typically not allowed at any use level.
Although many international markets follow FEMA guidelines, some countries adhere to different regulations on labeling of natural flavors in their products. As an example, companies in China don’t conform to FEMA but regulations there do allow GSGs to be added as flavoring.
Additionally, when looking to label stevia as a natural flavor, it isn’t recommended to combine it with multiple sweetness enhancers. This is particularly the case for Flavors with Modifying Properties (FMPs) such as stevia derivatives, monk fruit, erythritol, and allulose since the combination may produce too sweet a taste even at these low use levels. Of course, our experts always recommend reviewing with your regulatory and legal teams regarding the proper labeling of ingredients.
In need of more detailed guidance for your formulation? Partner with us and learn more about formulating with stevia and natural flavor labeling requirements. Contact one of our experts for your product development and formulation needs!