American Health & Medical Research Association
Labels decoded

Four kinds of label claims and what each proves

Every claim on a package falls into one of four groups, and knowing which group you are looking at tells you how much the words are worth.

Sources14, listed below Reading time12 minutes
On this page
  1. The four buckets
  2. Where the claims you actually meet land
  3. Five rules that survive any new marketing word
  4. What no claim on any package can tell you
  5. A procedure for a claim you've never seen
  6. When the label is the wrong thing to be reading
  7. The habit worth building

Pick up two boxes of cereal in the same aisle. One says “natural.” One says “organic.” They sit at the same eye level, printed in the same friendly type, and they read like the same kind of promise.

They are not the same kind of promise. “Organic” runs on a federal certification system with accredited agents, paperwork and four distinct labeling tiers. “Natural” on a food package rests on a policy position the Food and Drug Administration wrote down and never turned into a regulation.

Nothing on either box tells you which word somebody checked.

That is the real difficulty with package claims. It isn’t mainly that companies lie, though some do. It’s that regulated words and unregulated words get printed in the same spot, in the same size, in the same calm green, and shoppers read them as equally meaningful.

The cost of guessing is measurable. A 2022 study in the journal Appetite, led by researchers at the University of Milano-Bicocca with a co-author at Michigan State University, asked 415 people to judge how healthy a box of cookies was. Participants rated the organic cookie as about as healthy as a conventional one even when the organic version carried 14% more of the daily reference intake for sugar and 30% more for fat. Adding a traffic-light nutrition label did not erase the effect.

This article is the map for the rest of this section. It sorts claims into four groups, drops the words you meet on a shelf into those groups, and hands you a short procedure for any claim you have never seen before. Each individual term has its own article here, so what you get below is the placement and the principle, not the full argument.

The four buckets

Every claim term you run into belongs to one of four categories. Learning the categories beats memorizing definitions, because marketing invents new words every year and the categories never change.

Defined in regulation

A federal agency has written a rule. The rule says what the word means, who may use it, what has to be true before it goes on a package, and what happens when someone uses it wrongly. Often there’s a certification step, a required disclosure format, or both.

These claims are checkable. You can read the regulation. Sometimes you can look the company up in a public registry and confirm it is listed.

Governed by agency guidance

No rule defines the word. Instead an agency has published how it interprets the term: how it reads the claim, how it decides whether a particular use is deceptive, and what a company would need in hand to back it up.

Guidance has real force, because the thing being interpreted is deception law. But guidance is not a standard a product gets certified against. No inspector checks a package for compliance with guidance. Cases get brought one at a time, long after a product has been selling.

Certified by a private body

A private organization writes a standard, assesses products against it, and licenses a mark. Some of these programs are serious: a published standard, independent assessors, a testing or audit regime, and a public directory you can search. Some are a logo a company paid to display.

Government is not involved in most of them. The word “certified” by itself does not tell you which kind you’re holding.

Not defined at all

The word means whatever the company means by it. No agency has defined it, no rule governs it, and no outside body stands behind this particular use of it.

That is not automatically dishonest. It is unverifiable, which is a different problem and a far more common one.

Where the claims you meet land

This guide covers the placement, each with a pointer to the article that argues the case in full.

Organic sits squarely in bucket one

The Agricultural Marketing Service at the US Department of Agriculture runs it. An organic label has to be reviewed and approved by a USDA-accredited certifying agent before a company can use it, and products must be produced without excluded methods such as genetic engineering, ionizing radiation or sewage sludge.

The four tiers are the part most shoppers miss. “100 Percent Organic” means every ingredient qualifies, setting aside salt and water. Plain “Organic” means at least 95%. “Made with Organic ___” means at least 70% and may not carry the USDA seal anywhere on the package. Below 70%, a company may only name specific certified ingredients in the ingredient statement, with no seal and no “organic” on the front panel. Our article on organic certification walks through what that buys and what it doesn’t.

Bioengineered disclosure is regulated, and it hinges on one word

Under the National Bioengineered Food Disclosure Standard, announced in December 2018 under a law Congress passed in July 2016, bioengineered foods are those that contain detectable genetic material modified through certain laboratory techniques, where that material could not be produced by conventional breeding or found in nature.

“Detectable” is carrying enormous weight in that sentence. Companies can disclose with text, a symbol, a digital link or a text message. Note what is not in bucket one: “non-GMO” is a marketing phrase, and the familiar non-GMO seals come from private organizations, not from the government. See our article on non-GMO labeling.

“Natural” on food is guidance, not a rule

The FDA has never done rulemaking to define “natural.” It has a longstanding policy: nothing artificial or synthetic, including color additives of any origin, has been added to a food where you would not expect it.

Read what that policy leaves out, because it is the most useful fact on the whole package. It does not address how the food was grown, including pesticide use. It does not address processing methods such as pasteurization or irradiation. And whether “natural” signals any nutritional or other health benefit is a question FDA says it never took up. The comment period on defining the term closed in May 2016. Our “natural” article covers the rest, including the separate fact that meat and poultry labeling falls to a different agency.

Green claims are guidance about deception

The Federal Trade Commission’s Green Guides, at 16 CFR Part 260, explain how the agency decides whether an environmental claim misleads people. The regulation says flatly that unqualified general environmental benefit claims should not be made, because shoppers read them as sweeping and almost nobody can substantiate every reasonable interpretation.

The examples in the rule itself are the best teaching tool in federal labeling law. A brand name of “Eco-friendly,” standing alone, is deceptive. “Greener than our previous packaging” is deceptive when the only change is 15% less packaging weight. An ad showing a printer nestled in a bird’s nest in a forest can deceive through imagery alone, with no words at all. See our article on sustainability claims.

“Cruelty-free” is undefined, and the FDA says so plainly

On its cosmetics labeling page, the FDA writes that “the unrestricted use of these phrases by cosmetic companies is possible because there are no legal definitions for these terms.”

The practical consequence is the part to carry with you. A company may apply the claim only to the finished product while suppliers or contract labs handle any animal testing. And because many cosmetic raw materials were tested on animals years ago when they were first introduced, a manufacturer can use only those older materials and rest a cruelty-free claim on the fact that nothing is being tested now. Our cruelty-free article covers the private certification marks that try to close that gap.

“Clean” is undefined too

No US law defines “clean” in food or cosmetics. It is a marketing category.

Cosmetics oversight did change recently. Under the Modernization of Cosmetics Regulation Act of 2022, the FDA’s page describes facility registration renewed every two years, product listings with ingredients updated annually, records substantiating a product’s safety, reporting of serious adverse events within 15 business days, and authority to order a mandatory recall when a company refuses a voluntary one. None of that defines “clean.” See our article on clean beauty and clean eating claims.

“Non-toxic” is regulated in exactly one corner

This is the surprise. For art materials, “non-toxic” sits in bucket one. The Labeling of Hazardous Art Materials Act of 1988 amended the Federal Hazardous Substances Act and is codified at 16 CFR 1500.14(b)(8). Art materials must get a toxicological assessment at least every five years, the criteria used go to the Consumer Product Safety Commission, and a conformance statement referencing ASTM Practice D-4236 has to appear on the package. Separately, 16 CFR Part 1303 bans lead in paints and similar surface coatings above 0.009 percent, which is 90 parts per million.

On a face cream, a cleaning spray or a supplement bottle, “non-toxic” carries no comparable definition. Our article on that word explains why the same three syllables mean something auditable on a crayon box and almost nothing on a lotion.

“Third-party tested” is an unregulated phrase about a real activity

The phrase itself is in bucket four. Nobody defines it. The underlying work can be excellent or can be a single purchased certificate.

A serious program checks identity, meaning the ingredient is what the label calls it; potency, meaning the amount matches; and contamination, meaning specified contaminants are absent or below limits. Effectiveness is not one of the three things being checked. Our article on the phrase explains how to verify a claimed certification by looking the product up in the certifier’s own public directory rather than trusting the badge.

Five rules that survive any new marketing word

A claim about an input is not a claim about an outcome. Organic describes how food was produced. The bioengineered standard describes detectable genetic material. Neither one is a statement about your health, and the FDA has said outright that its “natural” policy never considered health benefits.

A claim about what’s absent says nothing about what’s present. “No parabens” is a fact about four letters on an ingredient list. What replaced them, at what dose, and whether any of it helps: none of that is in the phrase.

An unregulated word isn’t necessarily a lie. It’s unverifiable. Plenty of companies using undefined words are describing something they genuinely do. You just have no way to confirm it from the package, and neither does a regulator in advance.

The agency that governs a word depends on the product it’s printed on. The FDA handles food and cosmetics labeling. The USDA handles organic and bioengineered disclosure. The CPSC handles hazardous art materials. The FTC handles advertising. The same word on a cereal box and a face cream can be governed by different law, or by none.

A certification is worth what its standard and its audit are worth. Ask what the standard requires, who assesses it, how often, and whether you can look the product up. A mark with no searchable registry is a mark you cannot check. It’s also worth being fair here: most certifiers are funded by the companies they certify, and that’s the normal model rather than proof of corruption. It’s a reason to look at the standard, not a reason to dismiss every seal.

What no claim on any package can tell you

No label claim tells you a product works. Supplements don’t need FDA approval before they’re sold. The NIH Office of Dietary Supplements explains the structure: companies are responsible for holding evidence that products are safe and that claims are truthful, manufacturers must follow Good Manufacturing Practices, the FDA can act after a problem surfaces, and the FTC polices advertising.

Most shoppers believe something different. A 2015 analysis in Drug Testing and Analysis by a researcher at George Washington University reviewed the evidence on consumer beliefs and found people widely assume supplements are government-approved, tested for safety and effectiveness, analyzed for content, and accompanied by mandatory disclosure of known adverse effects. None of those assumptions matches the law.

No claim tells you dose, either, at least not always. When a Supplement Facts panel uses a proprietary blend, it shows only the total weight of the blend, with the ingredients listed underneath in descending order and no individual amounts. That’s legal. It also makes dose comparison across products impossible.

And a claim doesn’t get better when a person says it instead of a package. Marketers can’t use an endorsement to say something they’d be barred from saying in their own voice, a principle the FTC set out when it revised its Endorsement Guides in 2023. A disease claim isn’t laundered by putting it in someone’s mouth.

A procedure for a claim you’ve never seen

Five steps, in order. It takes about a minute at a shelf.

  1. Name the bucket. Is this word defined in regulation, interpreted in guidance, certified privately, or undefined? If you can’t tell, treat it as undefined until you can.
  2. Ask what it’s a claim about. Production method? Ingredient absence? Testing? A health result? Most claims are about inputs. Very few are about outcomes.
  3. Look for the checkable part. A seal with a registry, a certifying agent, a required disclosure format, a conformance statement. If there’s nothing checkable, you’re reading an assertion.
  4. Flip to the information panel. The ingredient list and the facts panel follow actual rules. The front of the package is designed by marketing. When the front and the panel disagree, believe the panel.
  5. Ask what the claim would have to mean to be worth the price difference. Often you can answer that in one sentence. Often the answer is nothing.

When the label is the wrong thing to be reading

Some situations make claim words irrelevant and the ingredient list urgent.

If you take a blood thinner, the words on the front of a supplement bottle don’t matter. Vitamin K can make warfarin work less well. St. John’s wort speeds the breakdown of many medicines. The NIH Office of Dietary Supplements lists both. Bring the actual bottle to your pharmacist or prescriber.

If you have surgery scheduled, disclose everything you take, including products you think of as food. Bleeding risk goes up with some of them, and anesthesia can behave differently.

And if you develop symptoms after starting a product, especially one marketed for weight loss, bodybuilding, sexual improvement or sleep, stop and call a clinician. The FDA has documented hidden pharmaceutical ingredients in products in those categories, with reported effects including sudden weight gain, gastrointestinal bleeding, raised blood sugar, liver toxicity and death. You can report a problem to the FDA through MedWatch. FDA publishes a list of tainted products, and warns in its own words that the list “covers only a small fraction” of them. Not being on it is not clearance.

The habit worth building

Before you pay a premium for a word, say out loud what you think the word guarantees. Then check which bucket it’s in.

If it’s in bucket one, you can confirm the guarantee. If it’s in bucket two, an agency has an opinion about honesty but nobody inspected this package. If it’s in bucket three, the guarantee is only as strong as a standard you haven’t read. And if it’s in bucket four, there’s no guarantee at all, just a sentence someone wrote.

That single question, asked in the aisle, does more than any list of definitions you could memorize.

Sources

  1. US Food and Drug Administration. “Use of the Term Natural on Food Labeling.” fda.gov
  2. US Department of Agriculture, Agricultural Marketing Service. “Labeling Organic Products.” ams.usda.gov
  3. US Department of Agriculture, Agricultural Marketing Service. “BE Disclosure (National Bioengineered Food Disclosure Standard).” ams.usda.gov
  4. US Food and Drug Administration. “Cruelty Free / Not Tested on Animals.” fda.gov
  5. Federal Trade Commission. “Green Guides.” ftc.gov
  6. Electronic Code of Federal Regulations. “16 CFR 260.4, General Environmental Benefit Claims.” ecfr.gov
  7. US Consumer Product Safety Commission. “Art Materials.” cpsc.gov
  8. US Food and Drug Administration. “Modernization of Cosmetics Regulation Act of 2022 (MoCRA).” fda.gov
  9. US Food and Drug Administration. “Dietary Supplement Labeling Guide: Chapter IV, Nutrition Labeling.” fda.gov
  10. National Institutes of Health, Office of Dietary Supplements. “Dietary Supplements: What You Need to Know.” ods.od.nih.gov
  11. Federal Trade Commission. “FTC's Endorsement Guides: What People Are Asking.” ftc.gov
  12. US Food and Drug Administration. “Avoiding Products Contaminated with Hidden Ingredients.” fda.gov
  13. PubMed. “Richetin J, Caputo V, Demartini E, Conner M, Perugini M. "Organic food labels bias food healthiness perceptions: Estimating healthiness equivalence using a Discrete Choice Experiment." Appetite, 2022. PubMed. DOI: 10.1016/j.appet.2022.105970.” doi.org
  14. PubMed. “Dodge T. "Consumers' perceptions of the dietary supplement health and education act: implications and recommendations." Drug Testing and Analysis, 2015. PubMed. DOI: 10.1002/dta.1857.” doi.org