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Leveraging the Regulatory Framework of Natural in Communications and Marketing
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Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

Jul 22, 2020

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Page 2: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

About Me!

Senior Regulatory Affairs Specialist with Nestle UK, responsible

for providing regulatory expertise to the food, cereal and food

service business divisions. Previously worked at the Food and

Drink Federation in the Scientific and Regulatory Affairs Division

focusing on food ingredient and additive issues.

Page 3: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

What is “Clean Label”?

Natural ingredients only?

Is it just about

what’s on back of

pack?

Does nutrition form part of

clean label?

Familiar (traditional?) processing

Familiar known ingredients, no “surprises”

No additives?

Kitchen cupboard

Goes beyond the ingredients list

Page 4: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

What is “Natural”?

Processing All Natural

Source

All natural ingredients

No artificial flavours, colours or preservatives

Flavourings are only ingredient regulated on natural (in EU)

“Real” ingredients

Page 5: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

Current Regulatory Status

• Except for general requirements of trading practices

acts, Regulatory authorities around the world have no

set definition for “clean label” or key elements such as

“natural”.

• Officially recognised Guidance exists but not in every

country and is variable in requirements.

Page 6: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

UK

• Major focus for company communications &

reformulation.

• Strong drive from “own brand”.

• Very influential media.

• FSA Guidance on “Criteria for use of…..Fresh, Pure,

Natural etc… (2008). Responsibility Deal.

• FDF Working Group on Natural

Guidance (2010)

Page 7: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

At all levels – local to global – companies are also

formulating their own internal guidance on “natural”

and “clean label”.

Page 8: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

Marketing Drive

• “Natural” statements = standard requirements.

• Product differentiation.

• Expanding natural to total look and feel.

• Pushing boundaries.

• Regulations may prevent

other types of claim.

Page 9: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

Finding Equilibrium

• There can be ups and

downs in finding

opportunities to truly

leverage natural in product

packaging and comms.

Page 10: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

Alignment is key!

Still room to play!

Marketing Push Regulatory Pull

Page 11: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

What could you do? Ideas!

• Promote/claim on key ingredients,

• Use pictorials,

• Tell the story,

• Simplify and rejig ingredients list (as possible),

But please don’t…….

• Interrupt the ingredients list,

• Show images or claims which can’t be substantiated.

Page 12: Leveraging the Regulatory Framework of Natural in ...d3hip0cp28w2tg.cloudfront.net/uploads/block_files/2014-11/sarah-dowding-1.pdfCurrent Regulatory Status • Except for general requirements

Plan, Plan, Plan

• Very important to think about the required claims up front

and plan them into a project.

• Don’t try to retro-fit claims to a product which has

already been formulated or re-formulated…..