What Are Natural Flavours? A Guide Under the Australia New Zealand Food Standards Code

In Australia and New Zealand, natural flavours are flavouring substances obtained from edible plant or animal sources through physical, microbiological or enzymatic processes. The Australia New Zealand Food Standards Code does not legally define the term, so flavours are listed in the ingredient statement simply as "flavour" or "flavouring", and any "natural" claim is policed under the Australian Consumer Law.

What the FSANZ Code Actually Says

The starting point for any AU or NZ labelling question is the Australia New Zealand Food Standards Code, Standard 1.2.4, which sets the rules for the statement of ingredients. Under Standard 1.2.4, most flavours and flavouring substances can be declared by their class name alone, the word "flavour" or "flavouring", without naming the individual aroma compounds and without an INS food additive number. The same point is made in plain English on the regulator's consumer page on labelling of food additives. That is why an ingredient list on an Australian or New Zealand product might read "sugar, water, citric acid, flavour" with no further breakdown of the flavour itself, even though the flavour may be built from dozens of individual aroma chemicals.

Why "Natural" Has No Legal Definition in the Code

What the Code does not do is define "natural" flavour. There is no legal definition in the Australia New Zealand Food Standards Code that distinguishes a natural flavour from a nature-identical or an artificial one, unlike the European Union (Regulation (EC) No 1334/2008) or the United States (21 CFR 101.22). The Code defines flavouring substances generically and does not divide them by origin. When Food Standards Australia New Zealand reviewed labelling some years ago, it considered codifying the natural and artificial distinction and decided not to. The practical consequence for a product developer is that you cannot point at a clause of the Code to justify a "natural flavour" claim on pack; the claim has to stand on its own evidence.

Natural, Nature-Identical and Artificial: an Industry Distinction

The natural, nature-identical and artificial distinction that the industry uses every day is an industry standard rather than a regulatory one. It is set out in the Codex Alimentarius Guidelines for the Use of Flavourings, CAC/GL 66-2008, maintained internationally by the International Organization of the Flavor Industry (IOFI) and adopted locally by the Flavour and Fragrance Association of Australia and New Zealand (FFAANZ). Under that industry framework, natural flavouring substances are obtained from plant or animal raw materials by physical, microbiological or enzymatic processes; nature-identical flavouring substances are chemically synthesised but identical to compounds naturally present in an edible source; and artificial flavouring substances are synthesised compounds not yet identified in nature. These categories are common language across briefs, datasheets and supplier specifications, but they sit beside the Code, not inside it.

How "Natural" Claims Are Policed in Australia

Because the Code is silent on the meaning of "natural", a "natural flavour" claim in Australia is policed in the same way any other marketing claim is. Section 18 of the Australian Consumer Law prohibits conduct in trade or commerce that is misleading or deceptive or likely to mislead or deceive, and the Australian Competition and Consumer Commission enforces it. The leading flavour-specific precedent is HBC Trading Australia Pty Ltd, which in 2021 paid A$26,640 in penalties after the ACCC issued two infringement notices over its Chef's Choice "alcohol free pure vanilla extract". The ACCC alleged the product was misleading because the word "pure" and images of vanilla beans on the label suggested a vanilla-bean origin when the flavour actually came from vanillin derived from clove oil, alongside added colour, glycerine and xanthan gum. HBC Trading also agreed to rename the product "vanilla flavouring". The detail is on the ACCC's media release. The lesson for any "natural", "pure" or origin-suggesting claim is the same: the overall impression has to match the product, including its name, its imagery and its ingredient origin.

What This Means for Product Labels

On the label itself, the Code's class-name approach makes flavours short on paper but does not relieve the maker of declaring everything else that travels with them. Flavours are declared as "flavour" or "flavouring" without INS numbers, but Standard 1.2.3 of the Code sets out warning statements, advisory statements and mandatory declarations that override the class-name shortcut for specific substances. Added caffeine has to be declared, and so do added glutamates and added ribonucleotides used as flavour enhancers when they are present in their own right rather than carried in only by an ingredient, because those carry their own consumer information requirements. Allergens are the other non-negotiable: any of the substances listed in the Code's allergen schedule must be declared when present in the food, including when they enter through a flavour or flavouring system, and that requirement runs regardless of how the rest of the flavour is named. Practically, a flavour supplier should be able to give you the allergen status, any declared additives, and any carryover ingredients on a single technical document, and a developer should expect to see it.

Evaluating a Natural-Flavour Claim

For a food or beverage maker thinking about a "natural flavour" claim on pack, the work is mostly evidence. Ask the flavour supplier for a written statement that the flavouring substances meet the natural definition in CAC/GL 66-2008, and ask for the source of each constituent, the process used to obtain it, and any carrier or solvent involved. Confirm that no nature-identical or artificial component is being grouped under the natural class on the specification. Check that the product name, the front-of-pack copy and the imagery on the design will not, taken together, suggest a different origin or composition than the flavour actually has. The HBC Trading case is the cautionary tale: the word, the picture and the source all have to align. Keep the substantiation in a single folder against the SKU so that a complaint, a retailer query or a regulator's request can be answered without rebuilding the file.

How VKA Australia Approaches Natural Flavours

VKA® Australia is an Australian flavour house. We develop and blend flavours in Southport, Queensland, with an Australian team and the global VKA group's flavour-science library behind us, which gives a local brief access to an international natural-flavour bank rather than starting from a blank page. Briefs are matched to the matrix and processing the product will actually see, so the profile holds through manufacture and shelf life rather than only at the bench. If you are working on a natural-flavour project for the Australian or New Zealand market, talk to our flavourists about a natural flavour project.