Defining Clean Food Label Trends
As consumers continue to strive toward "clean eating," the definition continues to evolve
The so-called “clean food movement,” like the foods it promotes, is growing and even thriving among some demographics. This involves foods and ingredients loosely defined by health seekers as unprocessed, without preservatives and with minimal sugar. However, as the clean label retail market grows, food entrepreneurs seek out new definitions of “clean,” allowing them to pave the way for untapped categories of food products.
Enter the latest clean label player: raw! Raw eating is portrayed as a “higher level” of clean eating. The idea is to eat food in its most “natural state;” with produce “pulled from the earth;” grains and seeds allowed to sprout; and then wrapped up in packaging and sold at organic supermarkets. It is not only free of any added ingredients, but billed as a “living” food containing its full complement of enzymes and probiotics. Eating raw, living food is considered the new generation of clean eating.
The FDA has no definition of raw, but it does reference it in its definition of “fresh.” As described in the FDA Code of Federal Regulations (CFR) Chapter 21, part 101-95, “Fresh, when used in a manner that suggests or implies that the food is unprocessed, means that the food in its raw state has not been frozen or subjected to any form of thermal processing or any other form of preservation, with the exception of some post-harvest pesticides, chlorine, and wax coatings.”
Because there is no direct description of raw, food companies have taken this as an opportunity to define the term in ways that assist the marketing and sales of their product, while explaining the benefits of their raw product. All too often, this comes without any hard scientific evidence or support.
The not-so-scientific raw food enthusiasts proclaim that uncooked and minimally processed foods have “living enzymes,” while food cooked any higher than 115°F is “dead.” While it’s true heat, acid, pressure, and other forces used in food processing denature proteins, and that enzymes are proteins and thus become denatured when exposed to said treatments, it is worth noting that the trip through the acid bath that is the human stomach and digestive system accomplishes pretty much the same thing.
Where raw foods have the greatest selling point is when it comes to probiotic cultures. Solid scientific evidence supports the advantages of living probiotics that promote a healthy gut and clean digestive system, as well as help promote immunity and other health benefits.
Until a decade or so ago, when ingredient scientists developed strains of probiotics that are resistant to high heat and other processing stresses, uncooked fermented foods and beverages were the only easily acquired non-dairy sources for live, friendly bacteria. These foods typically included yogurt, kefir, and cheese or kimchee, sauerkraut, miso and other fermented soy products, and similar items.
There are now whole aisles dedicated to raw or raw-like products in natural food supermarkets. Probably the most prominent players in this category are common snacks that have been consumed for years but have been either recreated or remarketed as raw. Examples of such snacks include household favorites like chocolate, energy bars, nuts, seeds, and dried fruits and vegetables—and trail mixes that combine them. They’ve been joined by cereal, chips, and crackers that clearly state they have not been roasted or cooked—just gently “air-dried.”
The word raw shows up frequently in product names like “Go Raw” or “Raw Revolution,” but many brands opt to leave out the word raw—for fear it could generate controversy with their consumers. They hope their descriptions of mild, low-heat treatments will inspire belief that their product is “alive and well.”
At what point a food crosses over to the cooked side depends largely on what that food is and its tolerance for heat. According to Living Intentions LLC, one of the largest raw food snack companies, if nuts and seeds can still sprout, then they are still alive. Living Intentions’ marketing efforts promote: “Sprouting creates life force, and through water activation…brings dormant seeds back to life.” Yet, the company confirms it uses pasteurized almonds for safety, although those pasteurized almonds still are able to sprout and are thus “still part of the living nut community.”
While improperly refrigerated low acid juices and vegetables have a higher safety risk, due to anaerobic bottling conditions and wet environments that support microbial growth, the shelf-stable raw aisle relies on the natural dry state, or that achieved by low-heat processing to still raw-friendly temperatures.
This is especially effective with nuts, seeds, and grains. Nut bars, trail mixes, and dried vegetable products, such as now ubiquitously popular kale chips, can all be dried to a water activity below aW0.8, which eliminates the pathogen risk.
A water activity between 0.6-0.8 still supports yeast and mold growth, but the FDA doesn’t get involved in ensuring product quality—it is strictly up to the manufacturer to safeguard against mold growth. Raw snack food companies must keep accurate records of all incoming ingredients to make sure they are not carrying high initial microbial loads. Without a kill step, starting materials need to be as clean as possible; finished products must be extremely dry.
The snack food category continues to grow, especially in the food for children category. Parents want healthy, unprocessed snacks for their kids, and developers are struggling to come up with clean, tasty and crunchy combinations that also last on the shelf.
Freeze-dried fruits and vegetables have been an expensive commodity, used almost exclusively in dry soup mixes or to give some value—i.e., added color to certain cereals. But a number of companies caught on to the value of the clean, minimally processed, kid-friendly and parent-approved snacking potential within freeze-drying technology. Coupled with the technologies that are lowering the cost of drying, and the past decade saw a surge in the number of products including or existing solely of dried fruit.
The freeze-drying process involves freezing of raw fruits and vegetables and then drying them under very low pressure and low temperature (120°F), allowing frozen water to sublime (escape the food as a gas) and not destroy the structure or flavor profile of the fragile unheated ingredients.
The low temperatures needed to create sublimation do not affect the quality or nutritional attributes of the food the way higher temperature dehydration methods do.
Freeze-dried fruits and vegetables are colorful and flavorful, and are as nutritious as their former pre-sublimed versions. Their attributes are, however, worth their weight in gold—literally. The cost to freeze dry is still somewhat prohibitive and, as a result, the retail market has primarily enjoyed the least expensive commodities, such as apples, corn, peas, and carrots.
These typically are sold in 1oz portions. While these still retail for several dollars or more per ounce, it is important to recognize that the whole fruit is approximately 90% water, making many such products competitive when compared on a pound-for-pound basis to the original amount of product involved.
Freeze-dried fruit and vegetable snacks are safe when they are dry, because the water-activity levels are so low (below aW0.3) that no bacterial growth can be supported. However the danger in freeze-dried foods comes is in mishandling by the consumer. For example, freeze-dried product that has a pH above 4.6 (such as many root vegetables) could be left exposed to the air, absorb moisture, and be consumed several days later by someone who might not be concerned that the texture is no longer crunchy. If the original product had high bacterial counts before it was dried, the pathogens could revive and multiply after having been temporarily dormant.
Other methods of fruit drying, such as dehydration and low heat (140°F), do cook the fruit, but investigators have researched different technology. “Although fruit ‘leather’ typically is cooked in oven, we have been evaluating the use of vacuum ovens to enable drying at lower temperatures,” notes Anibal Concha-Meyer, PhD, a food science researcher for the Centro de Estudios en Alimentos Procesados (CEAP) in Talca, Chile.
“Controlling the temperature and pressure during drying is important, because the fruit formulations, when subjected to high temperatures, lose significant amounts of their antioxidant content. The heat also adversely affects the sensory properties of the final product,” Concha-Meyer adds.
Concha-Meyer also notes that, “Working with emerging technologies to inactivate enzymatic browning and assure product safety is a trend of the future.” He also points out that, since most fruit bases are high-pectin products, it’s “always easier to work this kind of ingredient, as it will contribute to a better texture in the final product.” He specifically suggests apples, quince, guavas, and plums as good options.
Manufacturers of any lower heat processing method of raw product must therefore control for the initial bacterial load of the ingredients going into the dryer.
Moreover, packaging should inform consumers how to handle these types of products. Acidic fruits are not as high-risk, due to their natural acidity, but improper handling still can result in mold or visual spoilage appearing on the product.
Pickles always have been a popular condiment, existing in both fermented cold-pack or brined shelf-stable jars and cans. Due to renewed interest in probiotic and vinegar-infused foods, more companies are emerging in this category. Some, such as Pernicious Pickling Co., make everything from red onions to carrots to beets and beans in shelf-stable, hot-packed product lines.
Mama O’s Premium Kimchi LLC manufactures cold-pack, raw fermented Napa cabbage kimchi, as well as a fermented paste. Kimchi is typically made with fish paste, but several companies also now offer vegan versions. Genuine Grub Co. is another kimchi brand marketing to consumers who might not be familiar or partial to the spicy Korean cabbage staple. The company introduced “updated” kimchi products that employ flavors such as Mint-dill and Spicy Cucumber Apple.
Kombucha is a raw fermented tea that enjoyed a burst of popularity in the early 1990s. After some food-safety difficulties with “do it yourself” kits and fly-by-night manufacturers, it effectively disappeared until a few years ago. Today, kombucha has experienced huge growth in the beverage market and is now being produced by so many companies, there is an aisle dedicated to it in most natural food markets.
Kombucha is made by adding a symbiotic colony of bacteria and yeast (SCOBY) to plain, black, sugared tea and allowing it to ferment for several weeks at room temperature. As the bacteria ferments the sugar in the tea, acid and gas are produced. A finished kombucha will have a pH of 2.5-3.5 and taste like fizzy vinegar. A second fermentation can take place, if the kombucha maker adds additional fruit juice concentrate or other sugar-based ingredients to the mix.
Once the product is refrigerated, the bacteria growth slows down, and the product can last several weeks at refrigerated temperatures. The combination of refrigeration and very low pH (2.5 to 3.0) will prevent pathogens from growing. Manufacturers who don’t pasteurize proudly market their kombucha as “raw,” but many commercial kombuchas don’t specify if the product is pasteurized after fermentation.
Selling a mass-produced raw kombucha can be risky business, as any plant contamination could result in thousands of moldy bottles. Also, since pasteurization stops the fermentation process, failing to do so can result in an alcohol beverage since ethanol is what the fermentation converts to the acetic acid (vinegar) that constitutes a major component of kombucha. However, post-pasteurization will kill off all spoilage—as well as all the active bacteria, leaving the consumer drinking what amounts to nothing but flavored vinegar.
Processors wishing to create a truly probiotic kombucha could consider incorporating some of the new strains of hardy bacteria into their formulation.
Fermentation, low pH, and refrigerated temperatures protect raw kombucha from pathogenic bacteria. However, fresh-pressed fruit and vegetable drinks (“juicing”) is now a large market and can pose potential health risks; it also is being scrutinized by the FDA.
This group of beverages, made from vegetables, fruits, nuts, and other combinations of raw plant ingredients could end up have too high a pH to inhibit growth of pathogens, such as the hard-to-kill Clostridium botulinum, which produce potentially deadly toxins if not adequately heated bottled in anaerobic conditions. Fresh beverages need a kill step to ensure they will last on the shelf and not make anyone sick.
Enter high-pressure processing (HPP): a non-thermal pasteurization method that applies a high pressure of 400-600 mPA for 1-10 minutes, reducing several log cycles of spoilage microorganisms and pathogens in the raw drink. The final product is not actually heated and, thus, retains most (if not all) of its nutrients and flavors.
But can HPP products be considered raw food? While an HPP-manufactured beverage may not be called “fresh” by FDA definition, many HPP beverage companies have been billing their products as raw for years, because no one has yet debated that term. However, HPP-treated juice makers now are being targeted in a wave of lawsuits, forcing the question of what raw really means to be addressed.
To avoid being part of such controversy, Harmless Harvest Inc. brand of coconut water removed the “100% raw” from its label in August 2015. Without a USDA definition or certification, the company felt there was no way to truly and legally verify such products are indeed raw.
While HPP helps ensure product safety in naturally acidic and acidified environments, the process, especially as it applies to products with a pH above 4.6, has merited FDA scrutiny. Last December, Harmless Harvest stopped selling its HPP coconut water after receiving a warning letter from the FDA stating that the processes used in the company’s Thailand facility are in violation of the Juice Hazard Analysis and Critical Control Point (HACCP) Systems regulation. According to the letter, the company had not “adequately demonstrated a 5-log reduction of spores of Clostridium botulinum.”
As HPP juices continue to enter the market, the FDA will focus on the process to ensure safety is properly validated. It is possible that only high-acid or acidified fruit and vegetable blends will be allowed to be made and sold via HPP.
Another concern is that consumers will not keep HPP low-acid (high-pH) beverages at the proper refrigerated temperatures necessary to inhibit toxin production. The FDA remarked, “As a result of several instances of botulism poisoning from refrigerated carrot juice (a low-acid juice), the Agency recommends that a process be applied to low-acid juices that will ensure that Clostridium botulinum growth and toxin production will not occur, should the juice, as offered for sale by the processor, be kept unrefrigerated in distribution or by the consumer.”
The most effective way of ensuring a product is free of botulism and safe at room temperature is to subject the product to a thermal retort process. Thermal retort cooks to at least 250°F, rendering the product extremely well-cooked—and, of course, no longer raw.
Other non-thermal processes are being explored as alternatives to HPP, although they have yet to be utilized in mass-production manufacturing. Pulsed Electric Fields (PEF) is an energy-efficient alternative to HPP that uses short bursts of electricity for microbial inactivation and causes minimal effect on food-quality attributes.
Foods treated with PEF are placed between electrodes, while high-voltage pulses are applied for microseconds. The high voltage causes an electric field that inactivates bacteria. Products that are PEF-treated are comparable to thermal pasteurization. PEF’d fresh juices have a 21-day shelflife.
The PEF process was utilized by the Genesis Juice Co. as long ago as 2006, and the company actually pioneered the technology’s use in the US. However, Genesis converted to HPP when that method became more mainstream. Still, there are some juice manufacturers using the technology, like the American Beverage Corp. in the US and Orchard House Ltd. in the UK.
“Many companies are using [PEF] technology, but few will mention it on their label,” says Mark De Boevere, managing director of Pulsemaster BV, a Dutch company that specializes in PEF processing. He adds that consumers appear to be “prejudiced against electricity,” and the only company that does allude to using it refers to it as “Fresh Micro Pulse-Treatment.”
PEF-processed products are more widespread than is generally known, according to De Boevere, who notes that users include processors of juice products, potatoes, sugar beets, cotton seed oil, and infant milk powders.
“If these companies would be more open about their usage, perhaps this method would become more widespread in the US and help improve product safety in all food categories,” he says.
Another method of non-thermal pasteurization explored is Microwave-Assisted Thermal Sterilization (MATS), by 915 Labs LLC. MATS is the first microwave sterilization technique approved by the USDA. The process shortens typical cook times and improves the flavor, color, and nutritional value of the food. MATS is not yet on the market but is expected to launch in Asia and Australia by the end of this year and in the US by 2017.
Products treated via MATS can be subjected to enough heat at 250°F for total sterilization or pasteurized at a lower temperature for a long refrigerated shelflife. In all cases, the exposure to heat is less than traditional retort and pasteurization methods and results in a fresher tasting finished food product. 915 Labs currently has test-pilot-sized units located within AmeriQual Group LLC and Wornick Foods Co. The companies are conducting R&D trials for interested brand owners, as well as offering informative boot camps at upcoming trade shows in 2016.
Food and beverage makers continue to explore ways to treat products to maintain color, flavor, and integrity—yet also ensure their safety at refrigerated temperatures or their shelf-stability. All new methods are being researched by universities and food/beverage processing companies.
The market has been flooded with raw products or products that have raw-like benefits. These products are an extension of clean eating, as it presents food in an unprocessed form consumers equate to being cleaner and healthier. The health benefits of raw foods range from unsupportable “living enzyme” claims to real probiotic benefits.
There are food-safety risks associated with raw foods that can be combated by new and emerging technologies. Many are able to effectively reduce pathogenic microbial loads and improve a product’s refrigerated shelflife. The goal is to be able to manufacture raw products to be shelf-stable, while still maintaining proper flavor and nutrients.
Originally appeared in the April, 2016 issue of Prepared Foods as Raw!.
The Raw Truth
There is no agreement, even within the raw food community, about what the maximum temperature is that still allows food to be considered raw. Temperatures ranging from 104°-118°F have been presented as the highest temperatures allowed before the “life-giving enzymes” are inactivated and the food is “dead.” Since this concept is missing a few wheels on its nutrition science cart, the raw food industry is in need of a third-party verification system that can help define the meaning of raw for all foods and improve the fairness in how raw food products are marketed.
Most raw products, like nuts, seeds, and HPP juices, have built-in safety measures. The raw dairy industry, however, has not attempted to take advantage of such measures and prides itself on good handling practices (or feeding cows only the best green grass available) to ensure product safety.
Centers for Disease Control (CDC) data confirm outbreaks linked to raw milk are more common in states where raw milk is legal. Common pathogens such as Listeria, E. coli, Salmonella, and Campylobacter can be found in raw milk and could pose severe health risks and even death—especially when consumed by the elderly, immunocompromised, or young children. The number of outbreaks in the US caused by non-pasteurized (raw) milk increased from 30 in 2007-2009 to 51 in 2010-2012. Most of the outbreaks (77%) were caused by Campylobacter, and most cases (81%) occurred from consumption of non-pasteurized milk purchased from states where its sale was legal.
Raw-milk cheese, however, is a different story. Risks from properly handled, properly manufactured raw-milk cheeses have proven to be minimal. To be legal in the US, a cheese must be properly aged for at least 60 days. Properly aging cheeses restricts the environment for the growth of harmful bacteria through the production of lactic acid and promotes the flourishing of competing, beneficial bacteria. The CDC has recorded, on average, only a few incidents of illness per year traceable to raw-milk cheeses across the last couple of decades, and many of those cases involved un-aged cheeses, such as Mexican queso fresco.
Until recently, the only way to incorporate probiotics into food was to add them to products that were conducive to microbial growth, such as dairy products and certain fruit and vegetable items. Such food products typically support growth of bacteria, whether it’s desired or not. Lately, there have been a slew of products on the market that are shelf-stable and also contain live and active probiotics. This is due to the development of probiotic strains, such as Bacillus coagulans BC30, that are more resilient and better able to withstand thermal processing. These strains also are better equipped to survive in shelf-stable foods, including gummy bears, dried pasta, hot beverages, baked goods, and chocolate bars.
Not only do such strong probiotic bacteria make it through the intense conditions and temperatures of the manufacturing process used to make the food product, they survive the journey through the highly acidic digestive tract and reproduce effectively to provide gut-health benefits. The introduction of such hardy probiotics provides a way for food companies to avoid the unsafe nature of some raw foods and the potential for spoilage by using controlled, inoculated fermentation in their safer shelf-stable, heat-treated products. These products still are not considered raw, but they do have many of the benefits raw products bring to the marketing table.