Few phrases sell food like “all-natural.” And few phrases have generated more class-action litigation. The reason is a gap at the heart of food law: the FDA has never adopted a binding definition of “natural.” Into that vacuum have stepped the plaintiffs’ lawyers, who have built an entire practice area around the argument that a “natural” label is misleading. If your packaging leans on purity claims, you’re standing in one of the most active litigation zones in the industry.
The FDA’s only real guidance is an informal, decades-old policy: it doesn’t object to “natural” in foods that contain nothing artificial or synthetic that wouldn’t normally be expected to be there. That’s it, no regulation, no clear test, and almost nothing on how processing affects the claim.
That ambiguity is the whole game. Plaintiffs argue that even ingredients derived from natural sources become “synthetic” or “artificial” once they’re manufactured through industrial processes, so a “natural” front label clashes with the reality on the back label.
The single most common flashpoint is citric acid. Most commercial citric acid isn’t squeezed from citrus, it’s produced by fermenting a mold, Aspergillus niger. Plaintiffs seize on that to argue “all-natural” is false when citric acid appears in the ingredients. The courts, though, increasingly expect proof: in a 2025 decision from the U.S. District Court for the Southern District of Illinois, Vineyard v. La Terra Fina, the court dismissed a citric-acid claim because the plaintiff’s allegations that the specific citric acid used was synthetic were conclusory and speculative, not tied to facts about how that ingredient was actually sourced or made. Other frequent targets include xanthan gum and additives where the front-label promise and the back-label ingredient list appear to conflict.
The theory keeps expanding. In the spirits world, “100% agave” tequila claims have drawn a wave of suits using carbon-isotope lab testing to allege the product contains ethanol from other sugar sources, not just agave. One such case, Haschemie v. Cinco Spirits Group, was filed in the U.S. District Court for the Southern District of Florida in August 2025. Similar suits are pending against other major tequila brands on the same testing theory, suggesting this is a developing litigation front rather than a one-off. Major brands aren’t immune generally: even well-known snack labels have faced “all-natural” class actions.
The lesson from the case law isn’t “never say natural.” It’s “don’t make an absolute claim you can’t back up.” A few disciplines dramatically reduce your exposure.
Avoid unqualified absolutes unless you can fully substantiate them. “All-natural” and “100%” are the phrasings plaintiffs love most because they leave no room for nuance. Where possible, use qualified, accurate language, “made with real [ingredient],” “no artificial colors or flavors”, that says something specific and true rather than something sweeping and vulnerable.
Reconcile your front and back labels. A huge share of these suits are built on the simple gap between a purity claim on the front and a chemical-sounding ingredient on the back. Read your label the way a plaintiff’s lawyer will.
Document your sourcing. If you claim natural, keep the supplier documentation, specifications, and any third-party certifications that show why the claim is accurate. In the citric-acid cases, proof of how the ingredient was actually made can be the difference between dismissal and a settlement.
Audit regularly and act fast on demand letters. These cases often begin with a lawyer’s letter probing for weakness. A prompt, well-advised response, backed by substantiation you already have on file, changes the dynamic.
“Natural” isn’t going to be defined by the FDA any time soon, which means it will keep being defined, case by case, by litigation. The brands that treat every purity claim as something they might have to prove in court are the ones that rarely end up there.
Using “natural,” “clean,” or “pure” claims and want them to hold up? Malkin Law can audit your labels and substantiation before a demand letter arrives.
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