Some food additives found in common items in grocery stores in the United States are not allowed in Europe. Additionally, different drugs and hormones given to farm animals to promote growth or increase milk production are not permitted in the European Union.
Different continents have different laws concerning food additives. In the United States, the FDA has deemed certain additives to be safe, while in Europe these same additives are considered a cancer risk. It is important to be aware of these differences when eating food from different continents.
When It Comes to Additives, U.S. Regulators Focus on Probability, EU Considers Possibilities
According to Justin J. Kastner, PhD, associate professor in the department of diagnostic medicine and pathobiology at Kansas State University in Manhattan, Europeans take a more cautious approach to evaluating chemicals and additives than Americans do.
One key difference between the United States and the European Union is that the United States has been more focused on the probability of hazards or bad things occurring, while the European Union approach has been more precautionary; they give attention to not just the probability of something going wrong, but also the mere possibility.
Food Industry Lobbying Helps Shape Policy in the U.S.
“The European Union is more conservative in regulating food additives,” said Sheela Sathyanarayana, an expert on the subject. Sathyanarayana is currently serving on a US government panel that advises on chemicals.
Sathyanarayana says that another difference between the United States and Europe is that the food industry has a very strong lobbying presence in the United States, and that this difference often results in the creation of regulation and policy around additives that is different in the two regions.
FDA Lags Behind Europe in Updating Regulations and Reevaluating Additives
The United States Environmental Protection Agency (EPA) revised the Toxic Substances Control Act (TSCA) so that chemicals may be evaluated before they are put on the market, but this revision does not address the legacy of decades of chemicals that are already in circulation, says Sathyanarayana.
In contrast to the European food chemical review system, which recently implemented a system of reevaluating all approved food chemicals, the American system has not changed, according to Maegan McBride, MPH, science policy associate at the Center for Science in the Public Interest (CSPI) in Washington, D.C.
The Center for Science in the Public Interest is a consumer advocacy organization that was founded in 1971. The organization provides practical and science-based advice on food safety.
“Because the United States doesn't have a system in place for reevaluation, it means that certain chemicals haven't been reevaluated since they were first approved, which could have been any number of years ago,” says McBride. “It's important to reevaluate because the field of toxicology is always progressing,” she adds.
Consumer Preference Is Helping to Reduce Use of Food Additives
The food industry has changed in recent years as consumers have become more interested in healthy, natural, and organic food. “Almost every manufacturer has a natural or alternative product line,” says Sathyanarayana. She believes that this trend toward healthier food choices will continue in the future as manufacturers try to eliminate harmful ingredients from their products.
Food Additives and Cancer: What’s the Evidence?
According to McBride, it can be challenging to determine the cancer risk of additives in humans.
She says that it is unethical to conduct a randomized placebo-controlled trial in humans when there is a chemical of concern or it is suspected that the chemical is associated with an adverse outcome, such as cancer.
It would be unethical to give someone a substance that might hurt them. This makes it difficult to get very strong evidence in humans and why animal testing is common in these cases, or more observational studies in humans.
Although lab studies may not always be able to predict if a substance will cause cancer, most substances which are found to cause cancer in lab animals are also found to cause cancer in people, according to the American Cancer Society. Carcinogens often have a much higher effect on animals than on people, so it can be difficult to determine risk. However, the American Cancer Society believes that if a substance is found to cause cancer in animals, then it is reasonable to assume that lowering human exposure to that substance will reduce risk.
Chemicals and additives that are known to cause cancer in animals are sometimes called possible human carcinogens, according to the Centers for Disease Control and Prevention (CDC).
Additives That Are Banned in Europe That Are Allowed in the U.S.
Here’s a rundown of food additives that aren’t allowed in Europe but are still used in the United States:
Titanium Dioxide
This additive, which is used for coloring, can be found in Skittles, Starburst, baked goods, soups, broths, sauces, and sandwich spreads. “Titanium dioxide can build up over time — it isn’t excreted very well,” says Sathyanarayana.
“The additive has been shown to be genotoxic in studies” means that the additive has been shown to damage DNA in studies. “Genotoxicity refers to the ability of a chemical substance to damage DNA” means that genotoxicity is the ability of a chemical substance to damage DNA. “Which is the genetic material in all cells” means that DNA is the genetic material in all cells. “And it may lead to carcinogenic, or cancerous, effects” means that genotoxicity may lead to cancerous effects.
The European Food Safety Authority (EFSA) has announced that it no longer considers titanium dioxide to be a safe food additive, due to lack of evidence on its toxic effects. Although there is no conclusive evidence that titanium dioxide is harmful, the EFSA is unable to rule out the possibility that it may be genotoxic. Consequently, they have been unable to establish a safe level of daily intake for the additive.
Even though it's probable that the additive will be outlawed eventually according to the EFSA's suggestion, it hasn't occurred yet. The European Commission and Member States have yet to make that decision. As of now, neither the CSPI nor the EFSA have given suggestions on whether people should stop consuming titanium dioxide.
Potassium Bromate
This additive is used in white flour, bread, and rolls to increase the volume of the bread and give it a fine crumb (not crusty) structure. Most bromate rapidly breaks down to form bromide, which is harmless. However, bromate has been shown to cause cancer in animals, and trace amounts of the chemical may remain in bread which could potentially be a small health risk to consumers, says McBride.
Bromate has been banned in many countries around the world, but it is still used in Japan and the United States. The Center for Science in the Public Interest has petitioned the FDA to ban bromate, and they recommend that consumers avoid this additive. Many millers and bakers have stopped using bromate, but it is still used in California. The organization says that this is because a cancer warning may have to be included on the label.
In 1986, California creates a law called proposition 65 that requires businesses to provide warnings on product labels if some chemical in the product could potentially cause cancer, birth defects, or other reproductive harm. Some experts on food and product safety see California as a model or guide for this type of regulation.
Azodicarbonamide
This additive is typically found in bread and other baked goods that come in packages, McBride says.
CSPI claims that two dangerous chemicals are produced when azodicarbonamide is baked. One of these chemicals, semicarbazide, is not harmful to humans. However, the other chemical, urethane, is a known cancer-causing agent.
CSPI recommends avoiding azodicarbonamide because there is a small chance it is harmful, and it is not necessary for the food supply.
Butylated Hydroxyanisole (BHA) and Butylated Hydroxytoluene (BHT)
The additives prevent oils and fats in food from going bad, explains McBride.
There is a risk of cancer associated with BHA, according to her. A study conducted previously discovered that BHA caused cancer in the stomachs of rats and as a result, the IARC concluded that the additive should be classified as a carcinogen. In 2011, the U.S. Department of Health and Human Services reported that there was enough evidence to say that BHA is likely carcinogenic in humans. Because of this, the CSPI advises people to avoid consuming it.
The chemical cousin to BHA, BHT, is often used together according to the Environmental Working Group (EWG), a nonprofit that works to protect public health. It has been shown to cause developmental effects and thyroid changes in animals, and while it's not officially classified as a carcinogen, there have been studies where rats fed BHT have developed cancer.
The EWG suggests that BHT should be avoided, especially when it is used in conjunction with BHA.
