But, isn't all food functional?” This often-asked question expresses the confusion felt by many in the food industry over the concept of “functional foods.” Even “empty calorie” food and beverages provide needed calories, if little else, to the human body. And, at the other extreme, more than a few plants have historical use not only as a food but for their medicinal benefits as well. (See Functional Foods…Back to the Future, PF, March 2001, p. 35.)
The question becomes less abstract as regulations strive to define what types of direct or implied claims, whether they be disease, structure-function, nutrient content or health, can be made for a product. Which claims are permitted are determined by the category that a product falls into, such as dietary supplements, over-the-counter pharmaceuticals, “conventional” or medical foods. Even the category in which a company positions its product can be controversial. Would PepsiCo's SoBe line with non-GRAS (generally recognized as safe) botanicals be more appropriately positioned as a dietary supplement than as a conventional beverage?