NATURAL INGREDIENTS
highlighted the importance of considering the transition to natural ingredients as a re-engineering exercise as opposed to a simple substitution exercise. “The technical and compliance sides are, in reality, tightly linked,” he says. Udi pointed to dosage as being another challenge. “Getting a natural ingredient to deliver its functional benefits – such as fibre content, colour, moisture retention, structural bulking – without disrupting mouthfeel, sweetness perception or set, can typically take several rounds of iterative trial work. Ingredients capable of doing more than one job at once may help reduce the number of additives a formulator needs to source and validate, but it will not remove the trial-and-error phase itself,” he says. Udi believes that supply consistency is
a less-discussed challenge when it comes to the process of reformulation. Natural ingredients – particularly those from upcycled or agricultural byproduct streams – need batch-to-batch specification control that can be harder to guarantee at scale than with a standardised synthetic input. For this reason, it is important to set
FINDING A NATURAL ALTERNATIVE THAT
REPLICATES KEY TECHNICAL AND FUNCTIONAL
PERFORMANCE IS NOT ALWAYS EASY
aside time during a reformulation project for supplier qualification and traceability work, not just formulation testing. “On the compliance side, the core
problem is that natural and clean label are not legally defined terms in the UK or EU,” continues Udi. “That absence of a fixed definition is where most of the regulatory risk actually sits. You cannot rely on the term itself to carry any weight, so any naturalness-based claim will need its own independent substantiation.”
This issue becomes particularly acute when it comes to functional or health- adjacent ingredients. “In our experience, ingredients with promising underlying science – for example, fibre ingredients with fermentation or prebiotic-type data behind them – still cannot carry health claims commercially in the UK or EU without formal authorisation under the Nutrition and Health Claims framework, regardless of how strong the science looks. That gap between what a dataset suggests and what’s legally sayable is one of the most common traps we have seen confectionery manufacturers fall into, and it applies well beyond our own ingredient category,” continues Udi. He highlights three strategies that can be implemented to help ensure clean label recipes meet legislative requirements.
These are: • Build on-pack claims on defined nutrient-content thresholds and documented functional testing – a high-fibre ingredient, for example, can support a ‘high fibre’ or ‘source of fibre’ claim against fixed criteria –
20 • KENNEDY’S CONFECTION • AUGUST/SEPTEMBER 2026
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