Food additive regulations in the European Union and the United States differ significantly in terms of approval processes and risk management criteria.
The EU operates under the precautionary principle, requiring rigorous pre-market safety evaluations and often banning additives suspected of posing health risks until they are proven safe. The European Food Safety Authority (EFSA) reviews scientific data for additive approvals and mandates regular re-evaluation of existing additives.
In contrast, the U.S. Food and Drug Administration (FDA) generally permits the use of additives until sufficient evidence demonstrates a potential hazard, relying on the concept of “Generally Recognized As Safe” (GRAS) for many substances.
Food additives allowed in US that are banned in Europe
- Potassium bromate: Used as a dough conditioner in bread products to help strengthen the dough and make it rise higher. Current classified as "possibly carcinogenic to humans" by the The International Agency for Research on Cancer. Banned in the EU and also in Argentina, Nigeria, South Korea, India and China.
- Azodicarbonamide: Used as a dough conditioner to make dough tougher and bread whiter. Produces semicarbazide as a breakdown product, which may pose a slight cancer risk.
- Butylated hydroxyanisole (BHA): Used as a food preservative and flavor enhancer. Often found in fast foods, cereals, drink mixes, gum and snacks. Classified as "reasonably anticipated to be a human carcinogen" by National Institutes of Health.
- Brominated vegetable oil: Used in soda and citrus-flavored drinks as an emulsifier. Health concerns center on the accumulation of bromine in the thyroid, and the potential for transferring bromine to infants through nursing. Was classified in the US as Generally Recognized as Safe from 1956 to 1970, and was then moved to the "interim additive" classification. Was banned by California in 2023 and removed from the FDA's allowed additives list in July 2024. Has been banned in the EU since 2008, as well as in India, Canada, and Japan.
- Red 40 food coloring is banned in the EU.
- Yellow 6 food coloring must carry a health warning in the EU.
- Titanium dioxide was banned by the EU in 2022.