Caramel & GreenCounsel
Hey Caramel, have you ever thought about how the FDAās ānatural flavorā definition might affect the exotic spice blends youāre working on? Iāve been digging through the regs, and itās a maze of footnotes that could make or break a new dessert line. We could map out the fine print and make sure your recipes meet every clause before you hit the market. What do you think?
Yeah, thatās been on my mind. The natural flavor regs are a maze, especially when Iām mixing cinnamonācardamomācocoaāsomething. Letās pull the footnotes out and see where each spice landsāif itās a natural flavor, a flavoring, or a protected ingredient. Iāll line up the clauses and we can tweak the blends so they pass the FDA check and still taste like a dream.
Sounds like a planājust remember the footnote that says ācocoa can be considered a natural flavor only if itās 90% cocoa solids,ā and the one about cardamom that requires it to be extracted with a nonāsolvent method. We can map each spice against those lines and keep the blend on the safe side. Let me know which clause youāre wrestling with and weāll sketch out a compliance chart.
Iām wrestling with the 90āÆ% cocoa solids rule ā my usual darkāchocolate base is only about 85āÆ% now, so Iāll need to tweak the blend or source a higherāsolids batch. The cardamom extraction clause is another knot; I keep using the quick solvent method, so Iāll have to shift to a more compliant, nonāsolvent extraction. Once we map those out, weāll have a solid compliance chart.
Got itājust remember that quick solvent extraction usually falls under āflavoring,ā not ānatural flavor,ā so youāll need to either swap to an essential oil method or document the solvent residues to stay compliant. For the cocoa solids, you could add a small amount of highāsolid cocoa powder to bump the percentage up to 90āÆ% without changing the taste profile much. Weāll draft a small table that lists each spice, the clause it touches, and the required adjustment. That way you can keep the dreamy taste and still tick all the FDA boxes. Let me know the exact percentages youāre working with and Iāll crunch the numbers.
Right now my blend is 85āÆ% cocoa solids, 3āÆ% cardamom, 2āÆ% vanilla, 10āÆ% sugarācoconut mix. Iāll bump cocoa up to 90āÆ% by adding 5āÆ% highāsolid cocoa powder. For cardamom, Iāll switch from the quick solvent soak to a steamāinfused essentialāoil extraction, or if thatās too messy, Iāll document the solvent residue and add a āflavoringā label. Iāll draft a quick chart: cocoa ā 90āÆ% solids clause ā raise solids, cardamom ā nonāsolvent extraction clause ā change method, vanilla ā already natural, sugarācoconut ā both natural and flavoring, so thatās fine. Let me know if that hits the mark.
That looks solid, just doubleācheck the footnote that says sugarācoconut blends must be declared as āflavoringā if the coconut content is above 5āÆ%. The 5āÆ% highāsolid cocoa bump will get you over the 90āÆ% threshold, and switching to steamāinfused cardamom keeps the natural flavor claim. If you stick to those tweaks, the FDA spreadsheet should be all green. Good workākeep that spreadsheet updated!
Got it, Iāll flag the coconut blend as āflavoringā in the spreadsheet and make sure the 5āÆ% threshold is noted. Iāll add the 90āÆ% cocoa bump and switch the cardamom to steamāinfused. Spreadsheetās going to be green, I promise. Thanks for the headsāup!
Glad to hear the spreadsheetās heading toward greenājust remember to add a footnote that the steamāinfused cardamom is extracted under 30āÆĀ°C to keep the volatile compounds intact. Also, label the highāsolid cocoa batch with its exact % solids, so the audit trail is crystal clear. All set?
All setā30āÆĀ°C steamāinfusion noted, highāsolid cocoa batch stamped with 92āÆ% solids. Spreadsheetās got the audit trail clean. Iāll keep tweaking until itās all green. Thanks for the precision!
Sounds like youāre all setājust keep that audit trail tidy and youāll have the FDA happy. Good luck with the tweaks!