The question of how many food additives are currently approved in the U.S. by the FDA is not a simple one, as the answer involves navigating a complex regulatory landscape that includes more than just formal approvals. The U.S. food supply contains thousands of substances, governed by a two-tiered system under the Federal Food, Drug, and Cosmetic (FD&C) Act. A substance is either a food additive requiring specific pre-market approval from the FDA, or it is Generally Recognized as Safe (GRAS) and exempt from that process. This distinction is crucial to understanding the full scope of substances used in food.
The Two-Tiered System of Food Substances
The U.S. regulatory framework was established by the Food Additives Amendment of 1958, creating two primary pathways for substances in food: the food additive petition (FAP) and the Generally Recognized as Safe (GRAS) designation. Substances widely recognized as safe before 1958, like salt and sugar, were exempted based on their history of use.
Formally Approved Food Additives
For substances not considered GRAS, manufacturers must submit a Food Additive Petition (FAP) to the FDA with scientific evidence of safety under intended use conditions. The FDA reviews this data, including chemistry, toxicology, and environmental evaluations. Approval results in a regulation in the Code of Federal Regulations (CFR) specifying conditions of use.
Generally Recognized as Safe (GRAS) Substances
GRAS substances are exempt from the formal pre-market approval because qualified experts consider them safe. Companies can self-affirm GRAS status based on expert review, or they can voluntarily notify the FDA, which then reviews the data. Self-affirmed GRAS does not require FDA notification, leading to less public oversight compared to the FDA-notified pathway or formal additive approval. This lack of transparency for self-affirmed substances has drawn criticism, as many chemicals have entered the food supply through this less-regulated route.
The Petition Process: What the FDA Considers
The FAP process requires manufacturers to provide detailed scientific evidence. The FDA reviews several key elements, such as the additive's identity, manufacturing process, proposed uses and levels, safety data, intended technical effect, and potential environmental impact.
A Comparison of Regulatory Pathways
The difference in regulatory oversight between the FAP and GRAS processes makes quantifying the number of additives complex. The table below highlights key distinctions:
| Feature | Formally Approved (FAP) | Generally Recognized as Safe (GRAS) |
|---|---|---|
| Approval Process | Mandatory pre-market review and approval by the FDA. | Exempt from pre-market approval; relies on expert consensus. |
| Oversight Level | FDA conducts a thorough, publicly documented review culminating in a regulation. | Can be self-affirmed by manufacturers with or without notifying the FDA. |
| Basis for Safety | Robust scientific evidence submitted directly to the FDA. | Can be based on publicly available scientific evidence or a history of safe use before 1958. |
| Transparency | Public regulation detailing the conditions of use is published in the CFR. | FDA posts its "no questions" letters for notified substances; self-affirmed status can remain confidential. |
Counting the Additives: Why the Number is Not Simple
The precise count of all U.S. food additives is unclear because the often-cited figure of over 10,000 substances includes those in the GRAS category, many without recent FDA review. This includes numerous flavorings and substances with long histories of use. While the FDA maintains public lists for formally approved additives (like the EAFUS list) and notified GRAS substances, these do not include the thousands of self-affirmed GRAS substances not voluntarily submitted to the FDA. The absence of a single, comprehensive list makes a definitive total impossible. Furthermore, unlike the EU, the U.S. has no legal requirement for the FDA to regularly re-evaluate the safety of all food chemicals.
Conclusion: Navigating a Complex System
Ultimately, there is no single figure for how many food additives are currently approved in the U.S. by the FDA due to the agency's dual regulatory pathways: mandatory formal approval and the GRAS exemption. The GRAS system, particularly self-affirmation, allows manufacturers significant flexibility, leading to a much higher number of substances in food than those formally approved. Understanding this system is crucial for consumers. The FDA's official GRAS notice inventory provides more information on substances notified to the agency. For more information on the GRAS system, the FDA maintains an official GRAS notice inventory of substances notified to the agency.