Food Additives: The US Compared to the EU

• European Union (EU) and USA flags

How does the European Union (EU) only allow about 400 chemical food additives, while the United States has upwards of 10,000? Many of the same food manufacturers operate in these countries, yet their products differ. It is astonishing to compare the same product, by the same manufacturer, but see a different and shorter ingredient list on those items sold in Europe.

The difference: legislation and lobbying.

The US and the EU have very different philosophies on agricultural and manufacturing processes. Many practices allowed here are forbidden there. 

The EU maintains higher hygiene standards in raising and processing animals so that antibiotics and antibacterial chemicals are not needed as prevention or disinfection to reduce pathogens. Their focus is on prevention measures, rather than the use of chemicals, to ensure food safety.

Another difference is in crop production, for which the US utilizes 85 pesticides that are banned in the EU. The EU does not tolerate the level of pesticide residues that the US does, and bans some foods from the US if these levels exceed the EU’s limits.

The EU actually re-evaluated their allowed food chemicals in 2010 to determine if they were still safe. Therein lies a major difference in philosophy between these two entities:

In the EU, an additive has to be proven safe before being allowed. In other words, if they cannot show that an item is not harmful, it won’t be approved. Food labelling is also stricter and more transparent.

The US, on the other hand, allows additives until harm is definitively proven. Companies are allowed to monitor themselves without much oversight, and often without FDA approval. Food companies can put together their own panel to declare an additive as GRAS or “generally recognized as safe” without research or input from scientists or food experts. Nothing is done to ensure safety until a problem arises.

The European Food Safety Authority (EFSA) independently assesses risks for food safety in Europe and provides information to the European Commission, which implements food safety policy. The EFSA is not associated with any particular government and requires pre-market approval. These regulations apply to all the members of the EU.

In the US, the Food and Drug Administration (FDA), established in 1938, is responsible for food safety regulations. The FDA does not assess potential risk before approval. In 1958, an amendment allowed for the FDA to review food additives “unless the substance is generally recognized as safe (GRAS)”, thus circumventing FDA review. In other words, additives are “innocent until proven guilty.”

The EU is proactive; the US, retroactive.

The EU prioritizes the health of its citizens and the impact on the environment, in addition to requiring clear labelling of additives.

The US is often driven more by industry rather than by citizens.

The list is obviously very long in what is allowed in the US, but not in the EU. Food manufacturers have the formulations that do not use many of these additives. They make the same products differently for European countries that don’t allow them. 

Why are these unhealthy additives still used in the US, some of which were banned in Europe 20 years ago?

The food and beverage industry has a heavy lobbying presence in the US government. They spent over $29 million last year. These companies often directly affect policy. Policies that continue to allow harmful ingredients.

I will highlight some, listing those banned in Europe but still allowed here.

An array of multi-colored cupcakes, depicting the many food dye colors.

Food dyes -

Blue 1 & 2, Green 3, Red 3 and 40, and Yellow 5 & 6. 

You see these in many ultra-processed foods (think Skittles, a rainbow of colors and a rainbow of risks).

Although a few may still be used in the EU, they are clearly labelled, including the risk to children’s activity and attention, since they are thought to cause hyperactivity in kids.

Red dye 3 was banned in the US in cosmetic products in 1990, but not in food. It was removed from skin products, but continued to be allowed in ingested products, until last year. It was banned, but can continue until July 17, 2027. This dye remained in our foods for 37 years after harmful effects were found.

Preservatives allowed in the US but not in the EU:

Sulphur dioxide

Sodium nitrate

Potassium nitrate

Potassium bromate

Carrageenan

BHA (butylated hydroxyanisole

BHT (butylated hydroxytoluene)

BVO (brominated vegetable oil)

Olestra

Propylaraben

Some of these are potentially carcinogenic and some are endocrine disruptors (BHT, BHA, BVO). 

Other additives include:

Synthetic growth hormones

Titanium dioxide

BPA

Azodicarbonamide (ADA)

Numerous pesticides, e.g. glyphosate

Chlorine-washed chicken

Arsenic-based drugs

Antibiotics in livestock that are used for preventive measures, such as chloramphenicol

A vet preparing an antibiotic injection for cattle. The practice of hormone and antibiotic injections in livestock, for growth or prevention of infection, has been banned by the EU but continues in the US.

Some states have initiated additive bans on their own, despite these additives having FDA approval.

What else can we do?

1. Read ingredient labels. Look for items that are unhealthy. Educate yourself on the various names for the same additive. Look for long lists of additives.

2. Boycott items containing these chemicals. Refuse to support these companies financially by how you shop.

3. Eat as cleanly as possible, with fresh produce, organic when possible, and animal products that are hormone-free and antibiotic-free. 

4. Support legislation that restricts unhealthy additives in our food.

5. Support organizations that call for bans on unsafe additives. Sign petitions that call for the banning of harmful chemicals.

6. Cook more at home to know what is in your meals.

7. Minimize or avoid ultra-processed foods. 

8. Wash all produce.

9. Look for BPA-free products.

10. Realize that your child's dose of additives is greater than yours (see last week's article), so be wary of the additives you feed your child.

Remember that what you purchase or don’t purchase casts a vote for food manufacturers. 

Perhaps RFK will pattern our food regulations after the EU’s. That makes more sense than patterning vaccine schedules after Denmark’s.