Caramel & GreenCounsel
GreenCounsel GreenCounsel
Hey Caramel, have you ever thought about how the FDA’s ā€œnatural flavorā€ definition might affect the exotic spice blends you’re working on? I’ve been digging through the regs, and it’s 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?
Caramel Caramel
Yeah, that’s been on my mind. The natural flavor regs are a maze, especially when I’m mixing cinnamon‑cardamom‑cocoa‑something. Let’s pull the footnotes out and see where each spice lands—if it’s a natural flavor, a flavoring, or a protected ingredient. I’ll line up the clauses and we can tweak the blends so they pass the FDA check and still taste like a dream.
GreenCounsel GreenCounsel
Sounds like a plan—just remember the footnote that says ā€œcocoa can be considered a natural flavor only if it’s 90% cocoa solids,ā€ and the one about cardamom that requires it to be extracted with a non‑solvent method. We can map each spice against those lines and keep the blend on the safe side. Let me know which clause you’re wrestling with and we’ll sketch out a compliance chart.
Caramel Caramel
I’m wrestling with the 90 % cocoa solids rule – my usual dark‑chocolate base is only about 85 % now, so I’ll need to tweak the blend or source a higher‑solids batch. The cardamom extraction clause is another knot; I keep using the quick solvent method, so I’ll have to shift to a more compliant, non‑solvent extraction. Once we map those out, we’ll have a solid compliance chart.
GreenCounsel GreenCounsel
Got it—just remember that quick solvent extraction usually falls under ā€œflavoring,ā€ not ā€œnatural flavor,ā€ so you’ll 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 high‑solid cocoa powder to bump the percentage up to 90 % without changing the taste profile much. We’ll 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 you’re working with and I’ll crunch the numbers.
Caramel Caramel
Right now my blend is 85 % cocoa solids, 3 % cardamom, 2 % vanilla, 10 % sugar‑coconut mix. I’ll bump cocoa up to 90 % by adding 5 % high‑solid cocoa powder. For cardamom, I’ll switch from the quick solvent soak to a steam‑infused essential‑oil extraction, or if that’s too messy, I’ll document the solvent residue and add a ā€œflavoringā€ label. I’ll draft a quick chart: cocoa – 90 % solids clause – raise solids, cardamom – non‑solvent extraction clause – change method, vanilla – already natural, sugar‑coconut – both natural and flavoring, so that’s fine. Let me know if that hits the mark.
GreenCounsel GreenCounsel
That looks solid, just double‑check the footnote that says sugar‑coconut blends must be declared as ā€œflavoringā€ if the coconut content is above 5 %. The 5 % high‑solid cocoa bump will get you over the 90 % threshold, and switching to steam‑infused cardamom keeps the natural flavor claim. If you stick to those tweaks, the FDA spreadsheet should be all green. Good work—keep that spreadsheet updated!
Caramel Caramel
Got it, I’ll flag the coconut blend as ā€œflavoringā€ in the spreadsheet and make sure the 5 % threshold is noted. I’ll add the 90 % cocoa bump and switch the cardamom to steam‑infused. Spreadsheet’s going to be green, I promise. Thanks for the heads‑up!
GreenCounsel GreenCounsel
Glad to hear the spreadsheet’s heading toward green—just remember to add a footnote that the steam‑infused cardamom is extracted under 30 °C to keep the volatile compounds intact. Also, label the high‑solid cocoa batch with its exact % solids, so the audit trail is crystal clear. All set?
Caramel Caramel
All set—30 °C steam‑infusion noted, high‑solid cocoa batch stamped with 92 % solids. Spreadsheet’s got the audit trail clean. I’ll keep tweaking until it’s all green. Thanks for the precision!
GreenCounsel GreenCounsel
Sounds like you’re all set—just keep that audit trail tidy and you’ll have the FDA happy. Good luck with the tweaks!