EU vs AU/NZ: Food Additive Regulations
Comparing regulatory philosophies: The European Precautionary Principle versus the joint FSANZ (Food Standards Australia New Zealand) science-based risk assessment.
Factual Regulatory Reference
This database provides factual regulatory information compiled from official government sources. It does not constitute medical, nutritional, or safety advice. Regulatory status varies by country and is subject to change. Always refer to your local regulatory authority for the most current information.
Why These Differences Exist
Regulatory divergence isn't random — it reflects fundamentally different philosophies about food safety, scientific uncertainty, and the burden of proof.
European Union
The EU follows the Precautionary Principle: if there is scientific uncertainty about a substance's safety, it is restricted or banned until proven safe. EFSA conducts mandatory re-evaluations of all approved additives on a rolling schedule, and any additive can be suspended if new evidence raises concerns — even before conclusive proof of harm.
Australia / New Zealand
Food Standards Australia New Zealand (FSANZ) manages food additive regulation for both countries jointly. The system follows a risk-based approach with periodic reviews. FSANZ considers international assessments (JECFA, EFSA) but makes independent decisions. Australia has been notably stricter than the EU on certain color additives.
European Union Standards
Primary Authority
European Food Safety Authority (EFSA)
Philosophical Approach
Precautionary Principle: Additives are considered restricted until rigorous scientific evidence proves safety for specific uses. Regular re-evaluations are mandatory.
System
E-Number System (Regulation EC 1333/2008)
Australia & NZ Standards
Primary Authority
Food Standards Australia New Zealand (FSANZ)
Philosophical Approach
Science-Based Risk Assessment: Rigorous pre-market assessment for all new additives. Emphasis on protecting public health and providing adequate information for consumers.
System
ANZ Food Standards Code (Standard 1.3.1)
Additives with Different Regulatory Status
| Chemical / E-Number | Function | 🇪🇺 EU Status | 🇦🇺 AU/NZ Status |
|---|---|---|---|
| Erythrosine E127 | colour | approved | banned |
| Patent Blue V E131 | colour | approved | banned |
| Brilliant Black BN E151 | colour | approved | banned |
| Brown HT E155 | colour | approved | banned |
| Titanium Dioxide E171 | colour | banned | approved |
| Aluminium E173 | surface colorant | approved | banned |
| Lithol Rubine BK E180 | color | approved | restricted |
| Orceins E182 | color | approved | banned |
| Sodium Sorbate E201 | preservative | banned | approved |
| Biphenyl E230 | preservative (surface treatment) | approved | banned |
| Hexamethylenetetramine E239 | preservative | banned | approved |
| Octyl Gallate E311 | antioxidant | banned | approved |
| Dodecyl Gallate E312 | antioxidant | banned | approved |
| Stearyl Tartrate E483 | emulsifier | banned | approved |
| L-Cysteine E920 | flour treatment agent | banned | approved |
EU Approved, AU/NZ Banned
Data Verification & Methodology
EU Data
Verified against Regulation (EC) No 1333/2008 and latest EFSA Scientific Opinions.
AU/NZ Data
Verified against the Australia New Zealand Food Standards Code (Standard 1.3.1) via FSANZ.
Timeline
Status current as of April 2026. Global regulations are subject to frequent updates.
Scope
Informational only. This database is not a legal document or health advice.