Precaution vs. Proof: How the US and EU Differ on Food Safety
Precaution vs. Proof: How the US and EU Differ on Food Safety
Safe here. Banned there.
Welcome to Truth Be Told, the weekly food and fitness newsletter published by The Whole Truth Foods.
Editor’s note: Today's piece emerged from a question I had been thinking about for a long while during my own exploration of food safety and additives: How come some ingredients that are banned in one country are allowed in another? What's going on?
I asked Anushka Mukherjee—who works as a researcher with me at The Whole Truth Foods—to find out, and her piece is what she uncovered about the differing approaches to safety in the US and Europe. And it makes an important point: the ideas on what is safe to eat and the forces that shape it aren't just about science—it's about interpretation of that science and how you choose to look at it.
PS: Before you ask, yes, there's no mention of FSSAI or India here. We are exploring that bit and will write about it later.
Imagine biting into a sandwich. The bread is soft, with those perfect little air bubbles that make it so satisfying. Now, consider this: in some countries, the chemical used to create those air bubbles is the same one found in yoga mats and shoe soles.
This chemical is azodicarbonamide, or ADA. It's a common food additive in the United States, helping to create that ideal bread texture. But in Europe, you won't find it in any bakery. European food safety authorities have deemed it unsafe for consumption and banned its use in food.
ADA is just one example. Several other additives—like potassium bromate, titanium dioxide, and various food colourants—are still permitted in American products but banned by the EU.
This stark contrast in regulation raises an intriguing question: How can two of the world's leading regions come to such different conclusions on what constitutes "safe" food? Shouldn't food safety standards be consistent in our interconnected world? Is the US too relaxed, or is the EU too careful?
The answer lies in how these regions fundamentally approach the concept of food safety. At the heart of this divide are two regulatory bodies: the Food and Drug Administration (FDA) in the US and the European Food Safety Authority (EFSA) in the EU.
Let's look closer at how they've handled ADA.
The crux of the issue lies in what happens when ADA is heated during baking. Under high temperatures, ADA breaks down into two chemicals: semicarbazide and urethane. This is where concerns arise. The US Department of Health and Human Services classifies urethane as a potential human carcinogen. Semicarbazide, while showing toxicity in animal studies, has unclear effects on humans.
Faced with this evidence, the FDA and EFSA came to different conclusions:
The FDA determined that at permitted levels, the risk from ADA is negligible, deeming it safe for use in food products. This approach is based on demonstrating harm: unless significant harm is proven, ingredients aren't banned.
EU regulators, on the other hand, decided the potential risks outweigh the benefits. They applied the 'precautionary principle', which prioritises caution when there's scientific uncertainty about a substance's safety.
The case of ADA is not an isolated incident but rather a symptom of a broader difference in food safety philosophy between the US and EU. This fundamental difference extends far beyond a single additive and is deeply rooted in each region's regulatory framework.
In the US, the FDA's approach is rooted in a 1958 legislation that introduced the "Generally Recognized as Safe" (GRAS) status for food additives.
Originally intended for common ingredients like vinegar or salt—which are also used as additivies—GRAS now allows manufacturers to bypass the FDA's rigorous approval process for many additives. They can assemble their own expert panel to assess safety and send the results to FDA. Important note: sending this is completely voluntary.
As it happens, over the years, this ‘legislation of ease’ has made it possible for manufacturers to use GRAS for thousands of food additives without proper regulation or testing. As Chris Van Tulleken reveals in his book Ultra-Processed People, only ten applications have been made to the FDA for full approval of new substances since the year 2000, while 766 new food chemicals entered the market.
This means 98.7% of new chemicals were self-determined as safe by the companies producing them—with no regulatory oversight!
The EU's contrasting approach was shaped by food safety crises, particularly the BSE (Bovine Spongiform Encephalopathy) outbreak, commonly known as mad cow disease, in the 1980s and 90s.
The crisis unfolded gradually. At first, parts of the UK reported isolated cases of BSE in cattle. Soon, these numbers grew into hundreds, then thousands. Initially, authorities believed the disease only affected cattle and couldn't be transferred to humans, even through consumption of infected meat. The UK government confidently assured citizens of their safety.
However, this assurance proved tragically misguided. The disease had a long incubation period in humans, with symptoms only appearing after 4-5 years. By the late 90s, people began falling ill, and over 150 individuals died rapidly after contracting the human form of the disease.
This incident severely shook public trust in government oversight. The official response was widely criticised as slow and ignorant, leading to a crisis of confidence in food safety measures. In response, Europe implemented a series of sweeping policy reforms aimed at restoring public faith and overhauling how health risks in food products – including produce and meat – were assessed.
The EU created the “General Food Law” based on the precautionary principle, allowing regulators to act even when scientific evidence isn't conclusive – essentially, a “better safe than sorry” approach. They also established the EFSA in 2002 to rebuild trust through rigorous, science-based food safety assessments.
These different approaches between the US and EU have significant implications. Americans might be exposed to additives that Europeans are protected from, while Europeans might miss out on safe and helpful food innovations due to stricter rules.
Moreover, this disparity creates challenges for global food manufacturers who must navigate different standards for different markets.
So what should you do? Where should you place the burden of proof?
That’s for you to decide. I will leave with a thoughtful perspective from journalist Melanie Warner, which, full disclosure, aligns with our philosophy at The Whole Truth Foods, so we are obviously biased.
In the book Pandora's Lunchbox, she writes:
As a mom of two boys, I think about the risk of feeding our kids additives that are new to human diets and not well regulated. I'd rather not take the chance—especially when there are alternatives. I prefer foods without chemical preservatives or artificial colours. Better yet, fresh, unprocessed foods we can make at home.
What do we gain from these risks? Sure, it's easy to buy cheap, tasty foods that kids love. But when I weigh this against my kids' health and growth, it's no contest. Processed foods are designed to be irresistible and convenient, but the more you know about food additives, the less appealing they become.
The Bottom Line
As we continue to grapple with these complex issues, one thing remains clear: the question of food safety is far from black and white. The journey towards a universally "safe" food system is ongoing, and it begins with understanding the different approaches taken by regulators around the world.
So, the next time you bite into that perfectly textured sandwich, remember the story of ADA. It's a reminder that in the world of food safety, what's on your plate might depend on where in the world that plate is located.
Well articulated. I look forward to your note on where the FSSAI stands.
This is a good share! Would be looking forward to the Indian version 😅🧐