High Fructose Corn Syrup Is Natural.

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High fructose corn syrup is a natural sweetener: It is made from corn and contains no artificial ingredients or color additives. Like table sugar and honey, high fructose corn syrup contains fructose and glucose, which are found in many other naturally occurring foods.

HFCS is composed of sugars that are found in nature.
The sugars in HFCS-glucose and fructose-are found in nature in similar proportions as they are in HFCS. Table sugar (sucrose), honey, fruits and fruit juices are alternative and equivalent sources of the sugars found in HFCS.

HFCS is made from natural grains.
HFCS comes from corn, a natural food.

HFCS contains no artificial or synthetic substances.
HFCS does not contain artificial or synthetic substances, nor does HFCS contain any color additives.

HFCS meets the "natural" requirements of the U.S. Food and Drug Administration.
HFCS is considered a natural food ingredient under the U.S. Food and Drug Administration's definition of the term "natural." Under FDA rules, "natural" means that "nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in the food."1

FDA's "natural" policy is recognized by the world's food standards organization, CODEX Alimentarius.2

HFCS is considered natural under the National Organic Program.
HFCS satisfies the definition of natural in the National Organic Program.

Under the U.S. Department of Agriculture National Organic Program regulations, HFCS qualifies as a natural ingredient. The NOP regulation, like the FDA natural flavor regulation, defines nonsynthetic (natural) ingredients to include substances created by naturally occurring biological processes, such as the use of enzymes.

Consumers expect HFCS to be in natural food products.
HFCS is used as a sweetener in many processed food products that carry the "natural" label. Examples of products in which HFCS is commonly used and in which consumers would recognize its use include yogurts, breads, soft drinks, breakfast cereals, fruit juices, sauces and dressings, snack foods such as crackers, pretzels, and granola bars, ice cream, jams and preserves, and canned soups, among others.

HFCS is as natural as sugar.
Both HFCS and sugar require processing to make the final sweetener. The sugar refining process consists of numerous steps and process aids including: multiple clarifying steps with heat and lime, polymer flocculent and phosphoric acid; multiple evaporation steps; centrifugation; washing with pressure filtration or chemical treatment; and decolorization with carbon or bone char. Hydrochloric acid and sodium hydroxide, or enzymes are added to liquid sucrose to break the bond between glucose and fructose to make invert sugar.3 Sucrose from sugar beets is processed by similar methods.

HFCS is made from corn starch, which is separated from other kernel components through multiple grinding and screening steps, centrifugation and washing. The HFCS refining process utilizes multiple enzymes and consists of numerous steps including: multiple refining using membrane filters, carbon filters and ion-exchange columns; centrifugation; chromatographic separation; and multiple evaporation steps.

1 58 Fed. Reg. 2302, 2407 (Jan. 6, 1993). See also, e.g., 56 Fed. Reg. 60421, 60466-67 (Nov. 27, 1991).
2 Codex General Guidelines on Claims, CAC/GL 1-1979 (Rev. 1-1991; adopted by CODEX in 1979).
3 See generally Environmental Protection Agency, AP 42, Compilation of Air Pollutant Emission Factors, Vol. 1, § 9.10.1.1 Sugarcane Processing (5th ed.). See also J.H. Galloway, "History of sugar - Domestication to the 17th Century," abstracted from Annals of the Ass'n of Am. Geographers, Vol. 86, No. 4, at 682-706 (Dec. 1996); C.C. Chou, "Sugar refining processes and equipment," in Handbook of Sugar Refining: A Manual for the Design and Operation of Sugar Refining Facilities (2000). Lantic Sugar, Canada, "Overview of sugar refining at Montreal processing plant," available at http://www.lantic.ca/English/overview/montreal.html.

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