Here’s the honest reason I started paying close attention to food additives. After I had COVID, I went through a period of taste and smell disturbances, and something strange happened on the other side of it: I started noticing a weird, off aftertaste in chemically seasoned food that I’d never picked up on before. Suddenly, foods I used to eat without a second thought tasted “off” in a way I couldn’t quite explain to people who hadn’t experienced it.
As a pharmacist, sure, part of my interest is the science — I know how to look up which substances have documented health risks, like certain additives linked to cancer, and I want to avoid those for genuinely medical reasons. But if I’m honest, that’s not actually the root of it. The root is simpler: I just want to eat delicious food and taste it fully. I want a rich, colorful life, and good food is a huge part of that. Losing the ability to enjoy certain foods without noticing something “off” about them was what actually pushed me to start learning.
So that’s what this post is: what I’ve learned digging into how Japan, the US, and the EU each handle food additives. It became a genuine education for me, and I wanted to share it in case it’s useful for you too.
Quick Question: Do You Know How Many Food Additives Your Own Country Allows?
Try to guess before you keep reading. Most people I’ve asked have no idea — and the actual numbers tend to surprise people in both directions.
- The EU: around 411
- Japan: roughly 1,500, once you add up every category
- The US: more than 10,000 — some researchers estimate closer to 11,000
If that US number looks like a typo, it isn’t. I’ll get to why in a minute.
First, What’s a “Positive List”?
This term comes up constantly in food regulation, so it’s worth explaining clearly. A positive list system means nothing can be used as a food additive unless it’s specifically been reviewed and pre-approved first — the substance has to prove it’s safe before it’s allowed on the market. Japan and the EU both work this way. It’s the opposite of a “negative list,” where everything is allowed unless it’s been specifically banned.
Japan and the EU aren’t alone in this, either — Canada (through Health Canada) and Australia/New Zealand (through FSANZ) both use the same premarket-approval structure, requiring a formal safety review before any new additive can be sold. It’s genuinely the global norm, not a niche approach.
On paper, this sounds reassuring: government review before anything reaches your plate. Which is exactly why the US number above is so surprising, since the US technically claims to use a similar premarket-approval system too.
So Why Does the US Have So Many More?
The short answer: an exception that essentially swallowed the rule. US law includes a category called “Generally Recognized As Safe,” or GRAS, originally created in 1958 to exempt obviously safe, time-tested ingredients — vinegar, baking soda, black pepper — from full additive review.
In practice, though, a company can decide on its own that a new ingredient qualifies as GRAS — often using a paid expert panel it assembled itself — and start using it in food without ever notifying the FDA. This is called “self-affirmed GRAS,” and it’s completely legal. Companies can voluntarily submit a GRAS notification if they want an official FDA response, but nothing requires them to, and plenty simply don’t bother.
Roughly a third of the 10,000+ substances allowed in US food entered through this self-affirmed pathway — meaning the FDA never formally reviewed them, and in many cases never even saw the safety data behind the decision.
A Concrete Example
Potassium bromate, a dough conditioner used in some breads, is a good illustration. It’s been flagged as a possible carcinogen by the International Agency for Research on Cancer for over 25 years, and it’s banned in the EU, Canada, the UK, and several other countries. In the US, it remains legal federally — California passed a state-level ban that takes effect in 2027, but there’s still no nationwide prohibition.
Is Anything Changing?
Yes, and it’s genuinely in motion right now. In March 2025, then–Health and Human Services Secretary Robert F. Kennedy Jr. directed the FDA to explore eliminating the self-affirmed GRAS pathway entirely, calling it a loophole that lets untested chemicals enter the food supply without government or public knowledge. Several bills in Congress aim to end self-affirmation and require mandatory GRAS notification going forward. None of this has become law yet as of now, so it’s worth watching rather than assuming it’s already settled.
What This Means for How You Shop
None of this means every GRAS substance is dangerous — plenty are genuinely harmless, ordinary ingredients that just never went through a formal review because nobody felt they needed to. But “approved for use” carries a different, weaker guarantee in the US than the same phrase does in Japan or the EU. Practically, that shifts more responsibility onto you as the shopper:
- Ingredient lists matter more than country of origin or regulatory approval status
- A long list of unfamiliar chemical names is worth a second look, even if every one is technically legal
- “Clean label” or “no artificial ingredients” is a marketing claim, not a regulatory one — check the actual ingredient list rather than taking the label’s word for it
I’ll go deeper into how umami-related additives specifically are made, and what the actual safety data says about them, in the next couple of posts.
日本語要約
このテーマに向き合うようになったきっかけは、コロナ罹患後に味覚・嗅覚障害を経験し、その後、化学調味料に妙な雑味を感じるようになったという個人的な体験からでした。薬剤師として発がん性など健康リスクのある添加物を科学的に避けたい気持ちもありますが、根底にあるのは「美味しいものを美味しく食べたい」「彩り豊かな人生を送りたい」という、もっとシンプルな思いです。そこで、日本・米国・EUそれぞれの食品添加物の基準について調べてみました。品目数はEUが約411、日本が約1500、米国は1万〜1万1000以上とされています。「ポジティブリスト制度」(市場に出す前に安全性が事前審査されたものだけを使用可)は日本・EUだけでなく、カナダやオーストラリア/ニュージーランドでも採用されている、世界的にはむしろ標準的な仕組みですが、米国には「GRAS(一般的に安全と認められる)」という例外規定があり、企業が自ら安全と判断すれば、国に届け出ることなく使用を開始できる「自己証明GRAS」という抜け道があります。これが米国の品目数が突出して多い理由です。臭素酸カリウムのように、他国で禁止されている物質が米国では今も合法、というケースもあります。2025年には制度見直しの動きも始まっていますが、まだ法制化はされていません。
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