Article
Regulatory Compliance

It’s Pumpkin Time – Flavor Usage for Seasonal Beverages

Flavors used to reinforce natural or seasonal ingredients are regulated in over 100 global jurisdictions.

Several large chain beverage outlets have announced the arrival of the popular pumpkin spice latte along with other seasonal beverages. A comparison of several ingredient listings anonymized from various websites shows that the pumpkin in these beverages comes from pumpkin sauce and/or pumpkin puree blends that contain approximately 2% pumpkin, according to the ingredient statements. The rest of the pumpkin spice taste comes from natural flavors. Natural flavors are more shelf stable than fresh fruits or vegetable purees and can be produced in commercial volumes regardless of growing seasons. Interestingly, the U.S FDA has a lenient definition of pumpkin that was last revised in 1973 and allows “any articles prepared from golden-fleshed sweet squash or mixtures of squash and field pumpkin” to be designated as pumpkin.

Flavors, which are manufactured in hundreds of taste profiles, are used in many food and beverage products. The use of flavors can reinforce natural or seasonal ingredients such as pumpkin puree. Flavors are defined in the United States by the FDA under 21 CFR 101.22, and over 100 other global jurisdictions legislate flavors as well. While not always well understood, flavors offer a reliable way to consistently capture taste profiles in a shelf stable format. For example, they may also be used to enhance or intensify the taste of agricultural products such as pumpkin puree.

U.S. FDA 21 CFR 101.22 also sets forth labeling requirements for flavors and spices. Recently, there has been more consumer interest around flavors in terms of how they are identified and labeled. Within the broad definition of flavors, there are also provisions for natural, artificial and organic flavors, depending on specific market regulations.

About the Author

Julie Holt is a subject matter expert in the areas of food and beverage, additives and regulatory strategy. Ms. Holt’s expertise includes the beverage industry, with current consulting support across multiple beverage categories.

Holt has more than 25+ years of regulatory experience in the food and food ingredients industries and managed her own advisory firm, Scientific & Regulatory Solutions LLC, prior to joining FoodChain ID. As a consultant, she supported several food and beverage clients including a Fortune 50 company. Holt has provided global regulatory knowledge covering more than 200 countries. Her consulting efforts have supported global regulatory needs, R&D projects, sustainability goals and innovation initiatives.

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