Empirical Analysis of Consumers’ Understanding of “All Natural” and Its Relationship to Genetically Modified Organisms [GMOs]
Thomas J. Maronick, DBA, JD

Abstract
Food labeled “natural” or “all natural” is estimated to be a $40 Billion industry and that “all natural” is the second most-used claim on new American food products. The problem is that neither the FDA nor the FTC has ever defined the word “natural,” preferring, at least from the FDA perspective, to give informal guidelines that a food product labeled “natural” should be one where nothing artificial or synthetic has been added or included that would not normally be in the food. Moreover, since the FDA has taken the position that genetically modified organism (GMOs) are “not substantially different from non-genetically modified foods,” food marketers are not required to label their products if they contain GMOs. To address the issue, the historical background of “natural” labeling at the FDA, the FTC, and state legislatures and actions being taken related to GMOs are examined and then the results of an on-line survey of 800 consumers who buy items labeled “all natural” is described. The on-line survey assesses consumers’ understanding of “all natural” and their perception of express and/or implied claims of “all natural” on a consumer product and their perceptions of GMOs. Policy implications that flow from these findings are also discussed.

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