Food Additives

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Mama Santelli

The European Union, United States, Canada, and the Great Britain take somewhat different approaches to regulating food safety, particularly when it comes to food additives, chemicals, and other substances used in food production. While all systems are designed to protect consumers, they differ in how they evaluate potential risks and when restrictions may be imposed.

The European Union generally places greater emphasis on the precautionary principle. Under this approach, regulators can take preventive action when there is credible scientific concern about a substance, even when the available evidence has not established that the substance is definitively harmful. In other words, the absence of conclusive evidence that something is dangerous does not necessarily mean that it will be permitted for use. Depending on the substance and the circumstances, manufacturers may need to provide sufficient evidence of safety before a food additive or other substance can be authorized. This approach is intended to reduce potential risks to consumers before they become significant public-health problems.

The United States follows a different regulatory framework. The U.S. Food and Drug Administration (FDA) regulate food additives and other substances used in food, but U.S. law also includes the “Generally Recognized as Safe,” or GRAS, system. A substance can qualify as GRAS when qualified experts generally recognize, based on scientific information and experience, that it is safe for its intended use. Some GRAS determinations are made by manufacturers themselves, although companies can voluntarily notify the FDA of their conclusions. The FDA can also take action when it determines that a substance does not meet the applicable safety requirements.

Canada occupies a middle position between the European Union and the United States. Like the EU, Canada requires food additives to undergo a pre-market safety assessment before authorization. However, Canada's regulatory decisions do not always follow the EU's precautionary conclusions. In several cases, Canada permits substances that the EU has prohibited or withdrawn, bringing its regulatory outcomes closer to those of the United States.

Great Britain has retained much of the EU-derived food-additive framework but now makes its own regulatory decisions.