Nature Identical Milk Flavouring

About

What it is and where it shows up.

Nature identical milk flavouring is a chemically synthesised flavouring substance whose molecular structure is identical to flavour compounds found naturally in milk (e.g. diacetyl, delta-decalactone, butyric acid esters); it is produced in a laboratory rather than extracted from milk but is otherwise chemically indistinguishable from its natural counterpart. It is used in dairy-style beverages, confectionery, biscuits, and processed foods to impart or reinforce a characteristic creamy milk taste and aroma at low cost.

Safety summary

The regulatory and scientific consensus.

Nature identical flavourings are evaluated individually by JECFA (FAO/WHO) and, in the EU, by EFSA under Regulation (EC) No 1334/2008; constituents determined to present no safety concern at estimated intake levels are permitted without a numerical ADI. Because 'nature identical' describes a category rather than a single chemical, aggregate risk depends on the specific constituent molecules used; the EU abolished the formal 'nature-identical' sub-category in 2008 so individual substances are now assessed as 'flavouring substances' under a positive-list regime. No IARC classification applies to the category as a whole, and no documented systemic harm at typical dietary intake levels has been established for the category in the general adult population.

Regulatory landscape

What food-safety regulators have decided.

Jurisdiction	Status	Note
EFSA (European Food Safety Authority) (European Union)	Approved	Regulation (EC) No 1334/2008, applicable from 20 January 2011, abolished the formal 'nature-identical' sub-category; formerly nature-identical substances are now regulated as 'flavouring substances' under a positive Union list in Annex I. Individual constituent molecules must be evaluated and approved by EFSA before use. The term 'natural' may not be applied to chemically synthesised nature-identical substances.source
FSSAI (Food Safety and Standards Authority of India) (India)	Approved	FSSAI FSS (Food Product Standards and Food Additives) Regulations, 2011 and FSS (Labelling and Display) Regulations permit the use of natural, nature-identical, and artificial flavourings under Regulation 3.3.1(1). For nature-identical flavouring substances, only the class name ('flavours' or 'milk flavour') need be declared on the label; the common name of the specific chemical is not mandatory. Usage permitted in flavoured milk and other dairy products under Appendix A.source
FDA (Food and Drug Administration) (United States)	Approved	The US does not use the 'nature identical' classification; chemically synthesised substances identical to natural flavour compounds are assessed as either GRAS (often via FEMA GRAS) or approved food additives under 21 CFR. The FDA has not challenged FEMA GRAS listings for flavouring substances. Constituent molecules in milk-type flavourings (e.g. diacetyl, lactones) are individually listed. Manufacturers must limit usage to the minimum level necessary to achieve the desired flavouring effect.source

Who should approach with care

Whose guidance would steer them away.

Lactose Intolerance — Although nature-identical milk flavouring does not inherently contain lactose, it is frequently used in dairy-based products that do contain lactose; individuals should verify the full product formulation and carrier composition.

Other — Individuals with cow's milk protein allergy (CMPA) should exercise caution, as some milk flavouring blends may use dairy-derived carrier matrices or be processed on shared equipment; specific constituent disclosure is limited because only the class name must be declared on Indian labels.

Infants — FSSAI nutraceutical guidance explicitly states that products containing added flavourings are not recommended for infants under 5 years without medical oversight, as individual constituent safety margins are derived from adult dietary exposure data.

Research citations

The sources behind this verdict.

1FSSAI. Food Safety and Standards (Labelling and Display) Regulations – Version VIII, 2025. fssai.gov.in
2EFSA. Scientific Guidance on the data required for the risk assessment of flavourings to be used in or on foods, 2022. efsa.europa.eu
3PubMed. The safety evaluation of food flavouring substances: the role of metabolic studies, 2018. pmc.ncbi.nlm.nih.gov
4other. Regulation (EC) No 1334/2008 of the European Parliament and of the Council on flavourings and certain food ingredients with flavouring properties, 2008. eur-lex.europa.eu
5WHO. Codex Guidelines for the Use of Flavourings (CAC/GL 66-2008), 2008. fao.org

Independently researched5 citations