Comment by robotnikman
Comment by robotnikman 3 days ago
If a food additive is banned in the EU, it should be banned here IMO. The EU has a good track record on what should or should not be included in food
Comment by robotnikman 3 days ago
If a food additive is banned in the EU, it should be banned here IMO. The EU has a good track record on what should or should not be included in food
I don't know whether that's literally true, but I can certainly tell you that there is no point in banning stuff nobody in the EU is thinking of using anyway. US companies are way more "adventurous" with their additives, which makes regulation here even more important.
There are in fact several food dyes in the EU that are "banned" in the US.
Using the word "banned" though is misleading. Most things are not approved because no one has petitioned for approval, not because they were found harmful. This happens more in Europe than the US though because the US has GRAS.
This, exactly.
And to clarify, since it appears to not be well known even in the US, that GRAS = Generally Recognized As Safe[0], which isn't necessarily all that safe given the "testing" required to meet that "standard."
[0] https://en.wikipedia.org/wiki/Generally_recognized_as_safe
It is.
Approved in EU* but not US:
Quinoline yellow (E104), Azorubine/Carmoisine (E122), Ponceau 4R (E124), Patent blue V (E131), Green S (E142), Brilliant Black BN (E151), Vegetable Carbon (E153), Amaranth (E123), Brown FK (E154), Brown HT (E155) and now Red Dye No 3 (E127)
Approved in US, but not in EU:
Orange B**, Citrus Red No. 2 and FD&C Green No. 3.
* Some individual EU countries ban some of these
** Not used despite approval
All the additives you mention are permitted only for specific uses and/or highly regulated quantities. None are simply "approved in EU but not in US".
You can get more information on each of them here: https://ec.europa.eu/food/food-feed-portal/screen/food-addit...
Its not just that. Different ideas on how to regulate.
To add something to food in the EU, you need to prove FIRST it causes no harm. It follows the precautionary principle.
In the US, the FDA allows "similar compounds" rapid approval, allowing for the expansion of what's allowed without testing.
Here is the probably not too bad chatGPT summary
United States: Risk-Benefit Approach
General Approach:
The US Food and Drug Administration (FDA) operates under a risk-benefit analysis framework. This means additives can be approved if the benefits (e.g., preserving food, enhancing flavor) outweigh the potential risks when used as intended.
In some cases, manufacturers can self-certify an additive as "Generally Recognized as Safe" (GRAS) without requiring FDA pre-approval. This system relies heavily on the manufacturer's responsibility and scientific consensus among qualified experts. Approval Process:
Data Submission: Manufacturers submit safety data for new additives, but the level of evidence required can vary. For GRAS substances, companies may use existing studies or published research instead of conducting new, comprehensive tests.
Rapid Approvals: The GRAS system allows additives to be introduced more quickly, provided there is no immediate evidence of harm. This has led to criticism that some substances enter the market without sufficient independent oversight.
The differing approaches to food additive regulation in the EU and the US stem from distinct legal frameworks, principles, and processes for evaluating food safety. Here's a breakdown of how it works:
European Union: Precautionary Principle
General Approach:
The EU adheres to the Precautionary Principle, which means a substance must be proven safe before it is approved for use.
Manufacturers or entities seeking approval for a food additive must provide comprehensive scientific evidence to demonstrate that the additive is harmless to humans. Approval Process:
Scientific Evaluation: The European Food Safety Authority (EFSA) conducts a detailed risk assessment. Applicants must submit robust toxicological and safety data, including studies on metabolism, potential toxic effects, and exposure assessments.
Re-Evaluation: Even after approval, all additives are subject to periodic re-evaluation to ensure ongoing safety as new scientific evidence emerges.
look at the health of average person in EU vs US particularly related to food related disorders.
Include obesity, diabetes. Then move onto the GMOs and Roundup and how GMOs enabled mass use of Roundup. Roundup is now being looked into as a potential source of the increase in autism, dementia and other neurorelated conditions.
Keep digging.
"Glyphosate has been assessed 3 times in the EU. The first assessment resulted in initial approval of glyphosate in the EU in July 2002. The second assessment, which was carried out between 2012 and 2017, led to the first renewal of approval.
The most recent assessment was carried out between 2019 and 2023 by Member State Competent Authorities, the European Food Safety Authority (EFSA) and the European Chemicals Agency (ECHA), and showed that there is currently no scientific or legal justification for a ban. This led to the renewal of approval of glyphosate in 2023.
Under the conditions of approval and by following good agricultural practices, glyphosate is considered not to pose any harmful effects on human health or unacceptable effects on the environment."
https://food.ec.europa.eu/plants/pesticides/approval-active-...
Not to the same extent apparently because of GMO.
One category of GMO is called “Roundup ready”
It means crops that can take Roundup and survive at high concentrations of glyphosate while natural crops have some limit of concentration. That means higher usage in the US.
EU law works a bit different. EU law bans everything that has not been shown to be safe (or grandfathered in) while US allows everything that has not been shown to be dangerous. Neither system is perfect.
For example, Chia seeds where illegal in EU before 2020 (but you could still buy them). Not because it was dangerous but because no company had paid money to fund studies to prove that Chia seeds are not dangerous.