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FDA and USDA Shape the Future of "Natural" and "Non-GMO" Food Labeling

30 October 2026

The FDA is seeking industry insights on the use of "natural" in food labeling, while the USDA continues to develop its regulations for disclosing bioengineered foods. The agencies' overlapping jurisdiction over these labels leaves food manufacturers navigating an evolving landscape.

The intersection of "natural" and "non-GMO" labeling has proven tricky for manufacturers to navigate. While both terms are popular with consumers, their definitions remain fluid.

FDA's Longstanding "Natural" Policy

The FDA has maintained a decades-old position that "natural" on food labels means nothing artificial or synthetic has been added to the product. However, the agency has not defined the term in regulations. FDA's food labeling page specifies that the policy was not designed to address food production methods like pesticide use, or processing methods like pasteurization.

In 2015, FDA requested public comments on the term "natural," seeking input on whether consumers associate "natural" with "organic" or "healthy," and whether "natural" should apply only to single-ingredient foods. The agency has requested these comments but has not finalized its guidance.

"Natural" is often used interchangeably with "non-GMO" by consumers. Many assume "natural" means "non-GMO." FDA's labeling guidance and public requests emphasize that both terms should be truthful and non-misleading, but they do not provide concrete definitions.

FDA Cautions on "Non-GMO" Claims

Additionally, FDA's 2015 guidance on voluntary non-GMO labeling states that manufacturers may use truthful statements such as "Not bioengineered" or "Not genetically modified." However, FDA advises against "free" claims like "Non-GMO" or "GE free" because they imply a total absence unless a regulatory definition for "free" exists.

The agency says it will not object to use of the "GMO" acronym if the statement is true and not misleading.

USDA's Bioengineered Food Disclosure Mandate

Across government, the USDA was assigned responsibility for a national mandatory disclosure system for bioengineered foods by the 2016 National Bioengineered Food Disclosure Standard (NBFDS). The law amended the Agricultural Marketing Act and gave USDA's Agricultural Marketing Service jurisdiction.

FDA's 2015 non-GMO guidance states that FDA no longer has authority over voluntary labeling to disclose bioengineered material in foods derived from plants. However, FDA retains jurisdiction over labeling that discloses the absence of bioengineered content in any human food.

Unresolved Questions in USDA's Rule

A 2018 proposal from USDA on implementing the NBFDS left several questions open. The proposal acknowledges unresolved questions about thresholds and what modifications fall under the definition of bioengineering.

The law defines "bioengineering" as using in vitro recombinant DNA techniques, but under what circumstances? The proposal also did not specify whether highly refined ingredients like corn syrup or dextrose would require disclosure if they contain no detectable modified DNA. The USDA proposed exempting ingredients known to be bioengineered if they made up less than 5% of the product by weight.

Food companies are currently waiting for USDzA to hear their concerns and finalize the regulations. The proposed rule includes multiple compliance options, such as physical signs in stores, electronic links, and on-package text. However, many manufacturer's are balking at the costs of compliance especially for products meant to be shelf-stable long-term.

Labeling Implications

For now, food labels fall into a unique regulatory gray area, with FDA and USDA sharing jurisdiction. FDA's focus is on verifying that claims are honest and not misleading, while USDA's pending rules will require mandatory disclosure of bioengineered ingredients.

Third-party certifications, such as the Non-GMO Project, have become popular with consumers who wish to avoid bioengineered foods. However, the certification landscape is a patchwork, and not all claims are identical.

In the future, FDA and USDA may provide more guidance to harmonize the standards, but any changes are likely to be an evolution, as both agencies have moved cautiously to arrive at this point. Food manufacturers would be wise to monitor these developments and consult knowledgeable staff or outside counsel to ensure their labels comply.