Guidelines for Natural Flavor Labeling with Stevia

Guidelines for Natural Flavor Labeling with Stevia

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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.

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 IngredientFEMA Number and Guideline to Label as a Natural Flavor
Reb A 60FEMA 4771, Most applications < 30ppm, Gum < 200ppm
Reb A 80FEMA 4772, Most applications < 35ppm, Gum < 234ppm
Reb AFEMA 4601, Most applications < 30ppm, Milk < 45ppm, Cereal < 50ppm, Gum <200ppm, Meat < 75 ppm
Reb CFEMA 4720, Non-alcoholic beverages < 250ppm, Cereal < 400ppm, Gum < 0.1%, Jam < 300ppm
Reb D 95FEMA 4921, Most applications < 32.5ppm, Gum < 325ppm
Reb E 85FEMA 4936, Most applications < 45ppm
Reb M 80/85FEMA 4895/4957, Several applications < 20ppm
Reb M 90FEMA 4968, Most applications < 35ppm, Baked < 70ppm, Cereal < 100ppm, Milk products < 45ppm
Reb M 95FEMA 4922, Most applications < 24ppm, Gum < 240ppm
SteviosideFEMA 4763, Beverages < 35ppm, Baked and Candy < 65ppm, Sauces and snacks < 30ppm, Milk products < 55ppm, Gelatins and Puddings < 65ppm
Stevioside 70FEMA 4911, Most applications < 50ppm, Baked < 200ppm, Cereal < 250ppm
Reb B 95FEMA 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 NumberGSG Stevia Product TypeUsage Limits as Natural Flavor
FEMA 4728Glucosylated steviol glycosidesSee chart below
FEMA 4845Glucosylated stevia extractMost applications < 100ppm
FEMA 4876Enzyme-modified stevia, stevioside 20%See chart below
FEMA 4909Glucosylated steviol glycosides, 70-80%See chart below
FEMA 4910Glucosylated steviol glycosides, 40%Most applications < 135ppm
FEMA 4931Glucosylated steviol glycosides, 90%Most applications < 100ppm
FEMA 4947Glucosylated stevia extract 40% with 14% Rebaudioside AMost applications < 60ppm
FEMA 4950Stevia rebaudiana extract with Rebaudiosides A and MMost applications < 50ppm
FEMA 4951Glucosylated steviol glycosides 90% supraglucosylated rebaudioside AMost applications < 70ppm
FEMA 4952Glucosylated steviol glycosides 91% supraglucosylated rebaudioside DMost applications < 50ppm
FEMA 4953Glucosylated steviol glycosides 58% supraglucosylated steviosideMost applications < 100ppm
FEMA 4992Rubusosides enriched glucosylated steviol glycosidesMost applications < 170ppm

Natural Flavor Usage Limits (ppm) by GSG Stevia and by Product Application

GSG FEMA Number4728484548764909491049314947
Baked goods50010010013510060
Beverages, Non-Alcoholic1751001206513510060
Beverages, Alcoholic17510010013510060
Breakfast Cereals50010010013510060
Chewing Gum1500100100135100
Condiments and Relishes200100110135100
Confections and Frostings10010011013510060
Egg Products110
Fats and Oils18911013510060
Fish Products100
Frozen Dairy1331001206513510060
Fruit Ices13310010013510060
Gelatins and Puddings13310011013510060
Granulated Sugar60
Hard Candy13310011013510060
Instant Coffee and Tea1751001006513510060
Jams and Jellies20010011013510060
Meat Products100
Milk Products2251001206513510060
Nut Products17510010013510060
Other Grains13310010013510060
Processed Fruits20010011013510060
Processed Vegetables133100100135100
Reconstituted Vegetables133100100100
Seasonings and Flavors17510010013510060
Snack Foods13310010013510060
Soft Candy13310011013510060
Sugar Substitutes60
Sweet Sauces13310011013510060

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!

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