If you’ve traveled to another country in recent years, maybe you noticed that the food didn’t taste quite the same as food in the U.S. Flavor isn't the only thing that differs between countries; regulations on food safety
differ widely from one country or region to another.
What’s Different? Labels, Chemicals, Additives
Depending what country you’re in, the labels on your packaged food could contain detailed information, basic information, or not much information at all. According to the Center for Food Safety
, 64 countries
(labeling laws map) have made labeling of genetically engineered food products mandatory, and the U.S. is not one of them. From Russia to China to Brazil, if a product contains genetically engineered ingredients, the label must say so.
What your snack’s label says, though, is only half the battle. What about what’s actually inside that bag or carton? There is wide variation in the types of chemicals and additives permitted in food in different countries. For example, food dyes such as Red #40 and Yellow #5 are allowed in American products, but in Europe, they’re either not allowed or their presence must be indicated on the label. Bovine growth hormones rBGH or rBST
(about RBGH) are legal in the U.S., but in all European Union countries, as well as in Japan, Australia, New Zealand, and Canada, they’ve been banned.
The chemical azodicarbonamide
(FDA information page), used to bleach flour, is allowed in the U.S. but illegal in Europe and Australia. Potassium bromate
(news article), which strengthens baking dough, is banned in the E.U., China, Canada, and other countries. Brominated vegetable oil
(Mayo Clinic FAQ), an emulsifier for soda and sports drinks, is banned in more than 100 countries, but the U.S. is not one of them.
Chemicals in Food: the Regulatory Process
So where do the differences in food safety laws stem from? The answer may lie in the processes by which the laws are made. The U.S. government has a different approach than many countries for deciding whether chemicals can be present in food.
U.S. policies are primarily supply-driven, with production efficiency as a central goal. Rather than forbidding a chemical until it’s proven safe, U.S. laws are designed to allow chemicals until they’re proven harmful. Meat and poultry are regulated by the Food Safety and Inspection Service (FSIS) of the U.S. Department of Agriculture
(USDA), while all other foods are regulated by the Food and Drug Administration
(FDA). FDA approval is required for food additives, but to determine whether an additive is safe, the agency relies on studies done by food manufacturing companies. Manufacturers may have economic incentive to get their chemicals approved, which could cause a conflict of interest in their studies. However, some companies choose to go beyond governmental regulations and exclude legally permitted chemicals
(Nestle additives blog post) from their products.
Policies in many countries, including those of the European Union, are demand-driven, emphasizing consumer concerns about quality of both agricultural products and production methods. The E.U. abides by the precautionary principle
(SEHN description), which states that when there’s evidence of danger to human or environmental health, protective action should be taken even if scientific proof of harm has not yet been established. Countries like Japan and Australia also utilize the precautionary principle.
Analysis of Additives in Food
Despite their differences, food safety laws around the world aim to ensure the safety and health of consumers. Scientific tests and analysis are an integral part of the regulatory process. Gas chromatography
(GC) and gas chromatography-mass spectrometry (GC-MS) are commonly used to identify and measure additives in food products, as well as residue from pesticides and other contaminants as described in the following methods: Is food safety testing an issue you or your laboratory are struggling with? If so, I’d like to hear your thoughts and experiences.