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Sugar-free without sweeteners

Natural flavouring: what the term actually means

Natural flavouring, flavouring extract, flavouring substances: what these terms on the ingredients list mean and how flavour is created with no sugar.

What is a natural flavouring? Flavourings are ingredients added to food to give it a particular smell or taste, or to alter these. Natural flavourings must be derived from natural raw materials – but not necessarily from the food they are designed to taste like. This guide explains the differences between ‘flavouring’, ‘natural flavouring’, ‘natural grapefruit flavouring’ and ‘extract’.

What are flavourings?

Flavourings are defined in the EU Flavourings Regulation. These include flavouring substances, flavouring extracts, thermally derived reaction flavourings and mixtures thereof. Reaction flavourings are produced from ingredients that only develop flavour properties when heated – for example, frying and roasting flavourings are formed when glucose is heated with beef extract.

Only processed foods may be flavoured; flavourings are prohibited in unprocessed foods such as fruit, vegetables, meat and honey. The previous distinction between ‘artificial’ and ‘nature-identical’ flavourings no longer exists in food law.

The terms on the ingredients list

InformationWhat it means
FlavourA general term for all flavourings. If the label simply states ‘flavouring’, it can be assumed – according to ‘Lebensmittelklarheit’ – that it was chemically produced in a laboratory.
natural flavouringis derived from natural raw materials – plants, animals or micro-organisms – but not necessarily from food; the source material is not specified.
natural X flavouring, e.g. natural grapefruit flavouringAt least 95 per cent comes from the foodstuff in question.
natural X flavouring with other natural flavouringsless than 95 per cent comes from the foodstuff in question.
Extract, e.g. vanilla extractmade entirely from the raw material mentioned, with the same range of flavourings.

In the list of ingredients, there is no need to distinguish between different categories of flavourings; legally, ‘flavouring’ is sufficient. More specific details are optional – and in that case, the rules set out above apply.

What exactly ‘natural’ means

If a flavouring is described as ‘natural’, its flavouring components must consist solely of flavouring extracts and natural flavouring substances. If the name also specifies a source material, at least 95 per cent must be derived from that source material – so a ‘natural apple flavouring’ must consist of at least 95 per cent apples.

The remaining 5 per cent at most may be used to compensate for natural fluctuations or flavour losses, or to give the flavour a distinctive note, such as a fresher or fruitier one. A natural X flavour must taste distinctly of the foodstuff in question, but need not have the same range of flavour compounds.

The situation is different with ‘natural flavourings’ without additives: in these cases, the name of the source material does not match the flavour, which is why it is not specified. An example from the Consumer Advice Centre: a raspberry-flavoured flavouring made from sugar beet or wood chips. Genetic engineering techniques may also be used in the production of natural flavourings.

‘Apple flavouring’ without ‘natural’: a grey area

And what if the label simply says ‘apple flavouring’ without the word ‘natural’? This term is not clearly defined in the EU Flavourings Regulation. The German Flavouring Industry Association interprets it as a flavouring that tastes of apple – without any indication of the source material. Lebensmittelklarheit, on the other hand, assumes that consumers expect a flavouring made from apples; if at least 95 per cent of it comes from apples, it should in any case be labelled ‘natural apple flavouring’. In some cases, an ‘apple flavouring’ may not contain any apple at all. The Federation of German Consumer Organisations successfully secured a court order in a legal dispute to ban the use of the term ‘apple flavouring’.

Special cases: caffeine, quinine and smoke

Certain substances must not be concealed behind the term ‘flavouring’. Quinine and caffeine must be explicitly listed on the label as ‘quinine flavouring’ and ‘caffeine flavouring’ respectively. For smoke flavourings, the term ‘smoke flavouring’ is mandatory if they actually impart a smoky flavour to the food. Smoke flavourings have been banned for most foods since 1 July 2026; a transitional period applies to ham, fish and cheese until 1 July 2029.

How flavourings are extracted

Flavour extracts are obtained from natural raw materials, such as fruit or spices, using solvents such as water, alcohol or oil. A flavour extract contains the same range of flavour compounds as the source material and may also be described as a ‘natural X flavour’.

Manufacturers use flavourings because they guarantee a consistent taste and save on costs – as a result, fruit tea or berry muesli, for example, contain very little actual fruit. The Consumers’ Advice Centre is therefore calling for flavouring to always be clearly indicated on the front of the packet, for example with the words ‘flavoured’. According to their findings, flavourings are also found in places where one would not expect them, such as in pickled gherkins, margarine or tinned fish – and often additionally in products advertised as containing ‘extra fruit’.

Are natural flavourings a cause for concern?

There are strict rules governing flavourings. Certain substances listed in Annex III of the EU Flavourings Regulation – including coumarin, beta-asarone, safrole, pulegone and thujone – must not be added to foodstuffs as such due to their toxic properties. If they are naturally present in ingredients or flavourings, maximum levels apply to certain foods.

Because flavourings produced chemically or biotechnologically are generally cheaper than those derived from raw materials, there is, according to the LGL, a general incentive to mislead. Food safety authorities therefore check whether ‘natural’ really is natural: the Bavarian State Office for Health and Food Safety, for example, can determine – based on the ratio of certain molecular forms and isotopic ratios – whether a flavouring originates from a fruit or has been produced chemically or biotechnologically.

Do flavourings contain alcohol?

It can: Alcohol is one of the solvents used to extract flavourings. For soft drinks, the guidelines set an upper limit – they may contain no more than 2 g of alcohol per litre, derived from fruit components, flavourings or specifically fermented ingredients. This alcohol does not appear as a separate ingredient in the list of ingredients.

The flavours in our varieties

This is what it says on the labels of our three flavoured and energy-boosting varieties – Blackcurrant & Pomegranate:

VarietyFlavouring, as per the list of ingredientsWhat the information means
Pink Grapefruitnatural grapefruit flavouringat least 95 per cent grapefruit
Lime & Mintnatural lime flavouring and natural peppermint flavouringat least 95 per cent lime or peppermint respectively
Citrusnatural citrus flavouringat least 95 per cent citrus fruit
Energy – Blackcurrant & Pomegranatenatural flavouring, plus colouring concentrates from carrots and blackcurrantsmade from natural raw materials; source material not specified

The four varieties contain 0 g of sugar per 100 ml and no sweeteners – the flavour comes from flavourings, along with citric acid. According to the label, the still and sparkling varieties contain no flavourings.

Flavour no sugar

Flavourings add taste but no sweetness: the nutritional information table for our products lists 0 g of sugar. Soft drinks, on the other hand, always contain ingredients to give them a sweet taste, such as sugar or sweeteners, according to the guidelines. The guide ‘Sugar-free without sweeteners’ explains why we avoid both; details on how sugar and sweeteners are assessed can be found under ‘Sugar or stevia?’.

Frequently Asked Questions

What is a natural flavouring?

A flavouring derived from natural raw materials – plants, animals or micro-organisms. The source material is not specified and does not necessarily have to be the foodstuff it tastes like.

What is the difference between flavouring and natural flavouring?

‘Flavouring’ is the generic term; if only ‘flavouring’ appears in the list of ingredients, it can be assumed, according to Lebensmittelklarheit, that it has been produced chemically. ‘Natural flavouring’ is derived from natural raw materials.

Are natural flavourings really natural?

They are derived from natural raw materials, but not necessarily from foodstuffs – a raspberry flavour, for example, can come from sugar beet or wood chips, and genetic engineering techniques may also be used.

Does ‘natural lemon flavouring’ have to come from lemons?

Yes, at least 95 per cent. Otherwise, it must be labelled ‘natural lemon flavouring with other natural flavourings’.

What does ‘apple flavouring’ mean without the word ‘natural’?

The term is not clearly defined. According to the flavourings industry, such a flavouring tastes of apple; however, ‘food clarity’ indicates that it does not consist of at least 95 per cent apples and may, in some cases, contain no apple at all.

Do flavourings contain alcohol?

You can: Flavour extracts are obtained using alcohol, amongst other things. According to the guidelines, soft drinks contain no more than 2 g of alcohol per litre from fruit components, flavourings or fermented ingredients.

What flavours are in ACQUA REAPER?

Natural grapefruit flavouring in Pink Grapefruit, natural lime and peppermint flavouring in Lime & Mint, natural citrus flavouring in Citrus, and natural flavouring in Energy – blackcurrant & pomegranate.

View flavoured water

Sources

  1. Food Transparency (Federal Association of Consumer Organisations): What are flavourings?, as at 17 August 2022. lebensmittelklarheit.de
  2. Food Transparency (Federal Association of Consumer Organisations): Flavourings: plenty of flavour, fewer natural ingredients, as at 11 September 26. lebensmittelklarheit.de
  3. Food Clarity (Federal Association of Consumer Organisations): Extract or natural flavouring – what the differences are, as at 24 October 2018. lebensmittelklarheit.de
  4. Food Transparency (Federal Association of Consumer Organisations): Does ‘apple flavouring’ come from apples?, as at 18 August 2022. lebensmittelklarheit.de
  5. Bavarian State Office for Health and Food Safety (LGL): Flavourings in food – Basic principles, updated 17 January 2023. lgl.bayern.de
  6. German Food Codex Commission: Guidelines for Soft Drinks, revised version dated 10 April 24, BAnz AT 16 May 24 B3. deutsche-lebensmittelbuch-kommission.de
  7. ACQUA REAPER: Product labels, as at 26 July.
  8. Acqua Reaper: Product label for Energy Blackcurrant, as at 07/26.
  9. ACQUA REAPER: Product labels – Still and Sparkling, 26/08.

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