FDA hasnt defined the word "natural" for cosmetics, and cautioned it does not guarantee products or ingredients are "safe."

While labeling must be truthful and not misleading, the use of trade puffery is generally accepted within limits. However, implying "natural" for ingredients such as color additives, which by statute must be listed via a petitioning process, may invite regulatory scrutiny.

A color additive is a dye, pigment or other substance capable of imparting color when added or applied to a food, drug, cosmetic or to the human body. The legal definition can be found in Section 201(t) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) and provides exclusions as well. Color additives for use in food, drugs and cosmetics require premarket approval.

FDA has stated all color additives are synthetic. Of course, we must consider whether the color is "added." For example, consider a lotion formulated with cosmetic ingredients not intentionally added for color versus a lotion to which a color is intentionally added, e.g., D&C Red No. 33. The first situation would not require a declaration of the presence of color. On the other hand, the intentional addition of a coloring agent such as D&C Red No. 33 means the color must be declared in the ingredient declaration.

To elaborate, one may consider "natural color" as the inherent color of an ingredient not intentionally added for coloring and which is unimportant insofar as appearance, value, marketability or consumer acceptability. Meeting such a labeling designation can be a difficult challenge. To avoid regulatory attention, the wise policy is to ensure all color additives are appropriately listed in the ingredient declaration.