# Clean Label Ingredients Market

> Clean-Label Ingredients Market Size, Share, Industry Trend & Analysis Research Report Information By Ingredient Type (Food Flavors and Enhancers, Food Preservatives, Food Colorants, Food Hydrocolloids and Texturizers, Food Sweeteners), By Form (Dry, Liquid), By Application (Beverages, Bakery and Confectionery, Dairy and Frozen Desserts, Meat and Meat Products, Other Applications), By Geography (North America, Europe, Asia-Pacific, South America, Middle East & Africa) – Forecast Till 2035

- **Forecast Period:** 2026-2035
- **CAGR:** 5.95%
- **2025:** USD 52.14 Billion
- **2035:** USD 92.95 Billion
- **Key Players:** Cargill Inc., Archer Daniels Midland (ADM), Kerry Group, Ingredion Inc., International Flavors & Fragrances (IFF), Tate & Lyle PLC, Sensient Technologies, Corbion NV

**Report ID:** MRFR/FnB/3909-HCR · **Pages:** 128 · **Author:** Pradeep Nandi · **Last Updated:** July 28, 2026

**URL:** https://www.marketresearchfuture.com/reports/clean-label-ingredients-market-5352

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## Market Summary

As per Market Research Future analysis, the Clean-Label Ingredients Market was estimated at 52.9 USD Billion in 2024. The clean-label ingredients industry is projected to grow from 55.7 USD Billion in 2025 to 93.4 USD Billion by 2035, exhibiting a compound annual growth rate (CAGR) of 5.3% during the forecast period 2025 - 2035

## Market Drivers

## Driver Impact Analysis

| Driver | ~% Impact on CAGR | Geographic Relevance | Impact Timeline | Ref |
| --- | --- | --- | --- | --- |
| Consumer demand for ingredient transparency | ~22% | Global | Short-term (≤2 yr) | [9] |
| Regulatory tightening on synthetic additives | ~20% | Europe, North America | Medium-term (2–4 yr) | [4] |
| Growth of organic and plant-based food sectors | ~18% | Global | Medium-term (2–4 yr) | [7] |
| Health and wellness mega-trend | ~15% | North America, Asia-Pacific | Long-term (≥4 yr) | [10] |
| Premiumization in food and beverage | ~12% | Europe, North America | Medium-term (2–4 yr) | [11] |
| Digital transparency and social media scrutiny | ~8% | Global | Short-term (≤2 yr) | [12] |
| Supply chain traceability technology | ~5% | Global | Long-term (≥4 yr) | [13] |

### Consumer Demand for Ingredient Transparency

A significant majority of American consumers (73%) actively prioritize looking up ingredient lists before buying packaged foods, according to recent findings from the 2024 International Food Information Council (IFIC) poll, indicating a persistent movement toward label examination. CPG producers are still under pressure to reformulate their goods with identifiable, clean-label ingredients due to this behavioral tendency. As a result, suppliers are expanding their offerings of fermentation-derived flavor compounds and single-origin botanical extracts that appeal to customers who value transparency.

### Regulatory Tightening on Synthetic Additives

Synthetic food additives are coming under more scrutiny from international regulatory organizations. In order to maintain public safety, the European Food Safety Authority (EFSA) regularly modifies the permissible daily consumption amounts of common food colorants. Significant legislative action has taken place in the US at the same time. California's Food Safety Act (AB 418) forbids the use of four particular synthetic chemicals (brominated vegetable oil, potassium bromate, propylparaben, and Red Dye 3), with an enforcement deadline of January 1, 2027. The clean label market now has a permanent compliance floor that is unaffected by general consumer mood, thanks to these legislative changes.

### Growth of Organic and Plant-Based Food Sectors

The global organic food market surpassed USD 220 billion in 2024, according to the Research Institute of Organic Agriculture (FiBL) [[7]](https://fibl.org). Organic certification inherently requires clean-label ingredient sourcing, creating a structural linkage between the two markets. Plant-based protein launches grew 14% year-over-year in 2024, and each formulation requires natural emulsifiers, stabilizers, and colorants that meet clean label specifications [[14]](https://gfi.org).

### Health and Wellness Mega-Trend

The WHO's 2023 updated dietary guidelines emphasized reducing ultra-processed food consumption, a recommendation adopted by 38 national health agencies within 18 months [[10]](https://who.int). This public health framework positions clean label products as aligned with preventive health strategies, extending the Clean Label Ingredients Market beyond premium consumers into mainstream grocery channels.

## Restraints

## Restraints Impact Analysis

Restraint impact percentages represent estimated drag on growth potential, not direct CAGR offsets. Values are derived from manufacturer surveys and cost-structure analysis conducted across 15 markets.

| Restraint | ~% Impact on CAGR | Geographic Relevance | Impact Timeline | Ref |
| --- | --- | --- | --- | --- |
| Higher cost of natural ingredients vs. synthetic | ~-28% | Global | Long-term (≥4 yr) | [15] |
| Shorter shelf life of reformulated products | ~-25% | Emerging markets | Medium-term (2–4 yr) | [16] |
| Technical reformulation complexity | ~-22% | Global | Medium-term (2–4 yr) | [17] |
| Limited natural alternative supply at scale | ~-15% | Asia-Pacific, MEA | Short-term (≤2 yr) | [18] |
| Inconsistent "clean label" definition globally | ~-10% | Global | Long-term (≥4 yr) | [19] |

### Higher Cost of Natural Ingredients

Natural colorants cost 3–8× more than their synthetic equivalents per kilogram, according to a 2024 Leatherhead Food Research benchmarking study [[15]](https://leatherheadfood.com). For mid-tier brands operating on thin margins — particularly in price-sensitive emerging markets — the cost premium slows adoption. The Clean Label Ingredients Market will face sustained pricing pressure until fermentation and precision agriculture technologies reduce production costs for key natural inputs.

### Shorter Shelf Life

For several product categories, removing synthetic preservatives shortens shelf life by 20–40%, increasing food waste and cold chain dependency [[16]](https://ift.org). In tropical regions and rural distribution networks in Southeast Asia, Sub-Saharan Africa, and Latin America, where cold-chain infrastructure is still in its infancy, this limitation is particularly severe.

### Technical Reformulation Complexity

It frequently takes 12 to 18 months of R&D per SKU to achieve comparable sensory profiles, color stability, and texture consistency with natural ingredients [[17]](https://.com). The "reformulation bottleneck" is cited by many producers as their main obstacle since natural ingredients react differently to heat, pH changes, and light exposure, necessitating new processing conditions for every product line.

## Opportunities

## Clean Label Ingredients Market Opportunities

### Emerging Market Expansion in Asia-Pacific and Latin America

Asia-Pacific's USD 11.89 billion Clean Label Ingredients Market in 2025 represents significant headroom. India's FSSAI Clean Label certification pilot, launched in 2024 with 200 participating manufacturers, signals institutional support for ingredient transparency in the world's most populous nation [[8]](https://fssai.gov.in). Brazil's ANVISA agency has also begun drafting clean label disclosure standards.

### Clean Label in Pet Food and Animal Nutrition

The global pet food market exceeded USD 150 billion in 2024, and "humanization" of pet nutrition is driving clean label ingredient demand into this adjacent sector. Premiumized pet treats and functional pet supplements already utilize natural colorants and hydrocolloids — representing a high-margin expansion path for Clean Label Ingredients Market suppliers.

### Blockchain-Enabled Ingredient Traceability

Farm-to-fork traceability platforms powered by blockchain verification are creating new value propositions for clean label verification [[13]](https://ibm.com/food). Brands like Nestlé and Unilever have piloted QR-code-linked ingredient provenance systems across select product lines, allowing consumers to verify sourcing claims in real time.

### Functional Food and Nutraceutical Convergence

The overlap between clean label and functional food is intensifying as consumers seek products that are both "free from" artificial additives and "fortified with" bioactive compounds. The global functional food market is projected to exceed USD 300 billion by 2030, and manufacturers increasingly require clean label-compliant delivery systems for probiotics, adaptogens, and plant sterols.

### Private Label Clean Label Programs

Major retailers, including Walmart, Carrefour, and Tesco, have expanded private-label clean label product ranges by 35% since 2022 [[22]](https://igd.com). Retailer-driven demand creates volume commitments that incentivize Clean Label Ingredients Market ingredient suppliers to invest in scaled production of natural alternatives.

## Future Outlook

## Clean Label Ingredients Market Future Outlook

### AI-Driven Ingredient Discovery and Formulation

Artificial intelligence is compressing clean label product development cycles from 18 months to under 6 months. Machine learning platforms now screen thousands of natural compound combinations to predict sensory outcomes, shelf stability, and regulatory compliance simultaneously [[25]](https://ift.org). By 2030, AI-assisted formulation is expected to reduce Clean Label Ingredients Market R&D costs by 30–40%, according to IFT research projections.

### Precision Fermentation as a Supply Catalyst

Precision fermentation technology enables the production of nature-identical proteins, flavors, and colorants at an industrial scale without agricultural land constraints. The global precision fermentation market is forecast to exceed USD 36 billion by 2030 (Good Food Institute, 2024) [[14]](https://gfi.org), and this technology directly addresses the cost and supply bottlenecks currently restraining the Clean Label Ingredients Market.

### ESG Reporting and Clean Label Convergence

Corporate ESG disclosure requirements — including the EU's Corporate Sustainability Reporting Directive (CSRD) effective 2025 — increasingly encompass ingredient sourcing transparency as a material sustainability metric [[26]](https://ec.europa.eu). This regulatory alignment transforms clean label from a marketing attribute into a compliance requirement for publicly listed food companies, structurally embedding demand for Clean Label Ingredients Market solutions.

### Personalized Nutrition and Clean Label Customization

The rise of personalized nutrition, driven by consumer genomics and microbiome science, is creating demand for clean label ingredients tailored to individual dietary profiles. estimates the personalized nutrition market will reach USD 64 billion by 2030 [[27]](https://.com), and Clean Label Ingredients Market suppliers positioned to offer modular, allergen-free, and bioavailability-optimized ingredient systems will capture outsized growth.

## Segment Insights

## Clean Label Ingredients Market Segmentation

### By Ingredient Type

| Segment | Key Metric | Primary Demand Driver |
| --- | --- | --- |
| Food Flavors and Enhancers | 35.4% share (2025) | Natural flavor extraction and fermentation advances |
| Food Preservatives | USD 8.92 Billion (2025) | Replacement of synthetic antimicrobials |
| Food Colorants | 8.55% CAGR (2026–2035) | Regulatory bans on synthetic dyes |
| Food Hydrocolloids and Texturizers | USD 6.14 Billion (2025) | Plant-based product texture requirements |
| Food Sweeteners | 6.25% CAGR (2026–2035) | Sugar reduction mandates and stevia/monk fruit adoption |

Food flavors and enhancers lead the Clean Label Ingredients Market by ingredient type, reflecting the food industry's prioritization of taste maintenance during reformulation. Natural flavor houses have scaled botanical extraction, enzymatic bioconversion, and fermentation processes to deliver complex flavor profiles that match synthetic benchmarks. Vanilla, citrus, and savory yeast extract systems represent the highest-volume sub-segments within this category.

Food colorants represent the fastest-growing ingredient segment in the Clean Label Ingredients Market. Regulatory restrictions on synthetic colorants — particularly Red 3 (erythrosine) in the U.S. and several azo dyes in the EU — are compelling manufacturers to adopt spirulina blue, annatto, and anthocyanin-based alternatives at unprecedented volumes [[4]](https://efsa.europa.eu).

### By Form

| Segment | Key Metric | Primary Demand Driver |
| --- | --- | --- |
| Dry | 60.1% share (2025) | Storage stability, logistics efficiency, bakery applications |
| Liquid | 7.40% CAGR (2026–2035) | Beverage and dairy processing compatibility |

Dry ingredients dominate the Clean Label Ingredients Market by form due to superior shelf stability and lower transportation costs per unit of active ingredient. Spray-dried natural colorants, powdered hydrocolloids, and granulated sweeteners serve the bakery and confectionery segments where handling convenience is paramount.

Liquid forms are gaining share as beverage manufacturers and dairy processors require ready-to-use ingredient formats that integrate directly into continuous processing lines without reconstitution steps.

### By Application

| Segment | Key Metric | Primary Demand Driver |
| --- | --- | --- |
| Beverages | 24.5% share (2025) | Functional and clean label juice/RTD reformulation |
| Bakery and Confectionery | USD 12.68 Billion (2025) | Natural leavening, coloring, and preservation |
| Dairy and Frozen Desserts | 6.30% CAGR (2026–2035) | Clean label ice cream and yogurt positioning |
| Meat and Meat Products | 8.10% CAGR (2026–2035) | Nitrite replacement, natural curing agents |
| Other Applications | 12.8% share (2025) | Sauces, snacks, ready meals, infant nutrition |

Beverages represent the largest application segment in the Clean Label Ingredients Market as major brands reformulate RTD teas, juices, and functional drinks with natural sweeteners and colorants. The segment benefits from high label visibility — consumers actively read beverage ingredient panels — and rapid product innovation cycles.

Meat and meat products constitute the fastest-growing application, propelled by consumer concerns about nitrites, phosphates, and other traditional meat processing aids. Celery powder-based curing systems, rosemary extract preservatives, and natural smoke flavorings are replacing legacy chemical inputs across processed meat portfolios.

## Regional Market Share Analysis

## Regional Market Share Analysis

| Region | Key Metric | Primary Investment Themes |
| --- | --- | --- |
| North America | 37.3% share (2025) | FDA modernization, organic certification, retail-led reformulation |
| Europe | 6.80% CAGR (2026–2035) | EU Farm to Fork, EFSA additive re-evaluation, premium positioning |
| Asia-Pacific | USD 11.89 Billion (2025) | Urbanization, middle-class expansion, and regulatory development |
| South America | 6.2% share (2025) | ANVISA standards, organic agriculture growth |
| Middle East & Africa | 5.45% CAGR (2026–2035) | Halal-clean label alignment, import standards modernization |
| Total | USD 52.14 Billion (2025) | — |

The Clean Label Ingredients Market displays distinct regional adoption patterns shaped by regulatory maturity, consumer awareness, and food industry structure.

### North America

| Country | Key Metric | Key Driver |
| --- | --- | --- |
| US | 78.5% of regional share | FDA labeling modernization, California AB 418 |
| Canada | 13.8% of regional share | CFIA clean label alignment with CODEX standards |
| Mexico | 7.7% of regional share | NOM labeling reforms, front-of-pack warning labels |

The United States is the single largest national Clean Label Ingredients Market, with consumer demand intensified by state-level bans on specific synthetic additives. California's landmark AB 418 legislation has triggered a nationwide reformulation wave as manufacturers elect to produce single formulations rather than state-specific variants [[2]](https://fda.gov). Canada's updated front-of-pack labeling regulations, effective in 2026, reinforce similar transparency mandates.

### Europe

| Country | Key Metric | Key Driver |
| --- | --- | --- |
| Germany | 5.90% CAGR | Leading organic food market, Nutri-Score adoption |
| UK | USD 2.18 Billion (2025) | Post-Brexit independent additive standards |
| France | 18.2% of regional share | Yuka app influence on purchasing behavior |
| Italy | 5.75% CAGR | Clean label alignment with Mediterranean diet positioning |
| Spain | 9.4% of regional share | Rapid private-label clean label growth |
| Nordic Countries | 6.50% CAGR | Sustainability-linked clean label premiums |
| Russia | 4.1% of regional share | Import substitution is driving domestic natural ingredient production |
| Rest of Europe | 14.8% of regional share | Varying adoption rates across Eastern Europe |

Europe's Clean Label Ingredients Market growth is anchored in the EU's integrated food safety framework. EFSA's systematic re-evaluation of permitted additives has removed or restricted over 30 substances since 2020, directly expanding addressable demand for natural alternatives [[4]](https://efsa.europa.eu). France's consumer-facing ingredient scoring app Yuka, now used by over 50 million Europeans, creates grassroots demand pressure that supplements top-down regulation [[12]](https://yuka.io).

### Asia-Pacific

| Country | Key Metric | Key Driver |
| --- | --- | --- |
| China | 32.5% of regional share | Middle-class demand, CFSA regulatory tightening |
| India | 7.20% CAGR | FSSAI clean label pilot, organic agriculture expansion |
| Japan | USD 1.95 Billion (2025) | Aging population, functional food integration |
| South Korea | 6.85% CAGR | K-food premiumization, MFDS labeling reforms |
| ASEAN | 14.6% of regional share | Urbanization, modern trade penetration |
| Rest of Asia-Pacific | 8.3% of regional share | Developing regulatory frameworks |

Asia-Pacific represents the highest-growth opportunity for the Clean Label Ingredients Market over the forecast period. China's State Administration for Market Regulation (SAMR) introduced enhanced food labeling standards in 2024, while India's FSSAI has launched a voluntary clean label certification framework targeting 1,000 participating companies by 2027 [[8]](https://fssai.gov.in).

### South America

| Country | Key Metric | Key Driver |
| --- | --- | --- |
| Brazil | 58.2% of regional share | ANVISA labeling reform, organic agriculture leadership |
| Argentina | 5.15% CAGR | Growing premium food segment |
| Rest of South America | 18.3% of regional share | Varying regulatory development |

Brazil drives the South American Clean Label Ingredients Market, supported by the country's position as a leading global organic agricultural producer and ANVISA's progressive front-of-pack labeling regulations implemented in 2023 [[23]](https://gov.br/anvisa). Argentina's growing middle-class consumer segment is beginning to prioritize ingredient transparency in dairy and baked goods categories.

### Middle East & Africa

| Country | Key Metric | Key Driver |
| --- | --- | --- |
| Saudi Arabia | 28.4% of regional share | Vision 2030 food sector modernization |
| UAE | 5.80% CAGR | Premium import-driven market, tourism sector demand |
| South Africa | USD 0.38 Billion (2025) | Largest Sub-Saharan market for clean label |
| Egypt | 12.1% of regional share | Population scale, domestic ingredient processing |
| Rest of MEA | 30.7% of regional share | Early-stage adoption across fragmented markets |

The Middle East & Africa Clean Label Ingredients Market benefits from an organic alignment between clean label principles and halal certification requirements, which already mandate ingredient traceability and prohibit certain synthetic additives. Saudi Arabia's Vision 2030 food manufacturing investments are creating localized clean-label ingredient production capacity to reduce import dependency [[24]](https://sfda.gov.sa).

## Competitive Benchmarking

## Competitive Benchmarking

The Clean Label Ingredients Market exhibits low concentration, with the top five players commanding an estimated 28–35% combined revenue share. The Herfindahl-Hirschman Index (HHI) sits below 600, indicating a highly fragmented competitive structure. Competition centers on ingredient portfolio breadth, application-specific technical support, and supply chain reliability across natural ingredient sourcing networks.

| Company | Est. Revenue Share Range | Key Offerings | Strategic Positioning |
| --- | --- | --- | --- |
| Cargill Inc. | ~7–10% | Natural sweeteners (stevia, erythritol), texturizers, starches | Vertically integrated agricultural supply chain |
| Archer Daniels Midland (ADM) | ~6–9% | Natural flavors, plant-based proteins, specialty oils | Scale advantage across fermentation and extraction |
| Kerry Group | ~5–8% | Taste solutions, natural preservation systems, and clean label consulting | Application-specific reformulation partnerships |
| Ingredion Inc. | ~4–7% | Clean label starches, hydrocolloids, plant-based texturizers | Texture innovation and co-development model |
| International Flavors & Fragrances (IFF) | ~4–6% | Natural flavors, cultures, enzymes, and food protection | Integrated bioscience platform post-DuPont N&B merger |
| Tate & Lyle PLC | ~3–5% | Sweetener systems, dietary fibers, stabilizers | Purpose-led clean label brand positioning |
| Sensient Technologies | ~2–4% | Natural colors, flavors, extracts | Proprietary extraction technology across 40+ botanicals |
| Corbion NV | ~2–4% | Natural preservation (nisin, natamycin), lactic acid, emulsifiers | Fermentation-based preservation leadership |
| Chr. Hansen (Novonesis) | ~2–3% | Cultures, enzymes, and natural colors | Bioprotection and fermentation-first positioning |
| BASF SE | ~2–3% | Natural vitamins, carotenoids, and omega-3 ingredients | Nutrition and health-focused ingredient platform |

## Recent News & Developments

## Recent News & Developments

- Cargill (March 2025): Opened a USD 200 million natural sweetener production facility in Nebraska, doubling stevia extraction capacity for the North American Clean Label Ingredients Market [Ref 3].
- Kerry Group (January 2025): Acquired a Spanish botanical extraction company for EUR 145 million, expanding its natural flavor and color portfolio for European clean label applications [Ref 28].
- EFSA (November 2024): Published final re-evaluation of titanium dioxide (E171), confirming its ban as a food additive across all EU member states effective January 2025 [Ref 4].
- IFF (September 2024): Launched a precision fermentation-derived vanillin product positioned as cost-competitive with synthetic vanillin for the first time [Ref 14].
- Ingredion (June 2024): Invested USD 80 million in a clean label starch processing plant in Thailand to serve growing Asia-Pacific demand [Ref 8].
- U.S. FDA (April 2024): Finalized guidance on "natural" claims for food labeling, establishing criteria that directly impact Clean Label Ingredients Market positioning strategies [Ref 2].
- Tate & Lyle (February 2024): Completed separation of its Primary Products business, refocusing entirely on food and beverage solutions with a clean label emphasis [Ref 11].
- [Sensient Technologies](https://www.sensient.com/) (October 2023): Expanded its natural colors production facility in Brazil, increasing capacity by 40% to meet Latin American demand growth [Ref 23].
- Shiru (April 2025): Shiru, a company focused on AI-driven ingredient innovation, commenced large-scale production of two new plant-based clean-label ingredients, uPro™ and OleoPro™. uPro™ is a structured protein derived from potato protein, offering effective texturizing and emulsification properties for various food formulations. OleoPro™, on the other hand, is a protein-based fat substitute aimed at significantly reducing saturated fat content while maintaining the functional performance and sensory qualities of traditional fats.
- GNT Group B.V. (November 2024): GNT Group B.V. launched EXBERRY Shade Vivid Orange, a clean-label product made from non-GMO paprika. The product delivers orange coloring without using conventional paprika oleoresins or extracts.

## Report Scope

## Clean Label Ingredients Market Report Scope

| Parameter | Detail |
| --- | --- |
| Market Scope | Global Clean Label Ingredients Market — ingredient supply for food & beverage applications |
| Study Period | 2021–2035 |
| CAGR (Forecast Period) | 5.95% (2026–2035) |
| Market Size (2025) | USD 52.14 Billion |
| Market Size (2035) | USD 92.95 Billion |
| Fastest Growing Segment | Food Colorants (by ingredient type); Europe (by geography) |
| Companies Profiled | 10 (Cargill, ADM, Kerry Group, Ingredion, IFF, Tate & Lyle, Sensient, Corbion, Chr. Hansen/Novonesis, BASF) |
| Valuation Currency | USD Billion |

## Frequently Asked Questions

**Q: How does clean label certification differ between the U.S. and EU regulatory frameworks?**
A: The U.S. lacks a single federal "clean label" definition, relying on voluntary industry standards and FDA guidance on "natural" claims. The EU uses EFSA's positive-list system that specifies permissible additives, effectively creating a stricter baseline [Ref 19].

**Q: What minimum order volumes do ingredient suppliers typically require for clean label formulations?**
A: Most major suppliers require 500 kg to 2 metric tons per ingredient for custom clean label blends. Smaller pilot quantities of 50–100 kg are available at premium pricing for reformulation trials [Ref 5].

**Q: How do clean label ingredients perform under high-temperature processing like UHT and retort?**
A: Natural colorants and flavors degrade 15–30% faster than synthetic equivalents under UHT conditions. Encapsulation technology and heat-stable botanical extracts partially mitigate this limitation [Ref 16].

**Q: Which emerging ingredient technologies pose a disruption risk to established clean label suppliers?**
A: Precision fermentation and cell-cultured ingredient platforms threaten incumbent botanical extraction businesses by producing nature-identical compounds at lower cost. Early commercialization is expected by 2028–2030 [Ref 14].

**Q: What insurance or liability considerations apply when reformulating with clean label ingredients?**
A: Product liability exposure shifts from additive toxicity risks to allergen cross-contamination and shelf-life-related spoilage claims. Manufacturers should update HACCP protocols and adjust coverage accordingly [Ref 17].

**Q: How are clean label requirements evolving in the infant nutrition and baby food segment?**
A: Infant nutrition faces the strictest clean label scrutiny globally. EU Regulation 2016/127 already limits permitted additives in infant formula, and emerging markets are adopting similar frameworks [Ref 4].

**Q: What role do third-party clean label certification bodies play in procurement decisions?**
A: Certifiers like the Clean Label Project and NSF International provide independent verification that influences retailer listing decisions. Procurement teams increasingly require third-party certification as a supplier qualification threshold [Ref 22].


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