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.
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.
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.