Food Additives and REACH: How to Ensure Compliance with Legislation Without Unnecessary Complications

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Food additives, such as emulsifiers, preservatives, or thickeners, are subject not only to food legislation but also to the REACH regulation. This means that even food manufacturers and raw material processors must verify whether the substances used are properly registered, whether they have valid safety data sheets (SDS), and whether they are correctly classified according to CLP/GHS. The problem? Many companies are unaware that REACH also applies to additives approved for food use—and missing documentation can lead to penalties or production delays. How should you proceed to ensure that your raw materials meet all requirements?

REACH and food additives: Basic framework and obligations

Food additives, although primarily falling under European Union food regulations (e.g., Regulation (EC) No 1333/2008), must simultaneously comply with REACH requirements. This applies particularly to substances used not only in the food industry but also in other industrial sectors, such as emulsifiers, preservatives, or colorants. REACH focuses on the registration, evaluation, and authorization of chemical substances, emphasizing safe use and minimizing risks to health and the environment.

In practice, this means that manufacturers or importers of food additives must ensure the registration of substances they place on the market in quantities exceeding 1 tonne per year. Exceptions include substances already fully regulated by other legislation (e.g., direct food additives approved by EFSA). For substances used in the food industry, it is crucial to demonstrate their safety not only from the perspective of food legislation but also under REACH, especially if the same substance is used outside the food sector. This requires close cooperation between quality, regulatory, and development departments.

CLP and Safety Labelling: How to Communicate Risks Correctly

The CLP Regulation (Classification, Labelling and Packaging) harmonizes the classification, labelling, and packaging of chemical substances and mixtures in the EU, including those used as food additives. Although food additives are often exempt from certain CLP requirements (e.g., if they are intended exclusively for food purposes), manufacturers and distributors must ensure proper labelling in cases where the substance is also used in other applications.

CLP safety labels must include standardized pictograms, signal words ("Danger" or "Warning"), standard hazard statements (H-phrases), and safe handling instructions (P-phrases). For food additives that are also used in industrial processes (e.g., as processing aids), it is essential to ensure that the labelling corresponds to their actual use and risk profile. This applies particularly to substances with toxicological or ecotoxicological properties, which may require special handling precautions.

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Safety Data Sheets (SDS): A key document for suppliers and customers

The Safety Data Sheet (SDS) is a fundamental document that suppliers of food additives must provide to their customers if the substance or mixture meets the criteria for classification as hazardous under CLP. The SDS contains 16 mandatory sections that detail physico-chemical properties, health and environmental risks, safe handling measures, first aid, and disposal. For food additives, the SDS is particularly essential in cases where the substance is also used outside the food sector, such as in cosmetics or cleaning agents.

In practice, the SDS must be continuously updated according to the latest substance data. This includes, for example, new toxicological studies, changes in classification, or updates to safety measures. For manufacturers of food additives, it is important that the SDS contains clear information on usage restrictions, especially if the substance is approved only for specific food applications. Customers can then use the SDS to assess risks in their production processes and ensure compliance with internal safety regulations.

Practical Tips for Ensuring Compliance with Legislation Without Unnecessary Complications

The first step toward seamless legislative compliance is a thorough analysis of your food additive portfolio from the perspective of REACH and CLP. Identify which substances fall under the registration obligation and verify whether they are already registered with the European Chemicals Agency (ECHA). For substances used exclusively in the food industry, focus on documenting exemptions and usage restrictions. It is also advisable to regularly update safety data sheets and ensure they contain all relevant information for specific applications.

Another key measure is training employees who handle food additives. They should be familiar with REACH and CLP requirements, as well as the content of safety data sheets, to correctly interpret risks and follow safety procedures. Last but not least, it is important to maintain open communication with suppliers and customers. Suppliers should provide transparent information about the composition and safety of their products, while customers should be able to demonstrate that they use substances in compliance with legislation. This minimizes risks and ensures the smooth operation of the supply chain.

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Exemptions for food additives from REACH registration: When and why exemptions apply

Food additives often fall under specific exemptions from mandatory registration under the REACH regulation, but this exemption is neither automatic nor universal. The key criterion is the primary purpose of the substance – if its main function is use in food (e.g., emulsifiers, preservatives, colorants), it may be exempt from registration under Article 2(7)(b) of REACH. However, this does not mean that the substance is entirely outside the scope of regulation. Manufacturers and importers must demonstrate that the additive meets safety requirements under food legislation (e.g., Regulation (EC) No 1333/2008 on food additives) and that it is not used for other industrial purposes that would require registration.

Particular caution is required for substances with dual use – for example, citric acid, which is used both as a food additive (E330) and in cleaning agents. In such cases, the substance must be registered for non-food applications if its annual volume exceeds 1 tonne. For suppliers, it is essential to maintain accurate records of the intended use and sales volumes to avoid misunderstandings during inspections by regulatory authorities. The exemption also does not relieve the obligation to comply with CLP requirements and provide safety data sheets for industrial applications.

How to Verify Supplier Compliance with REACH: A Checklist for Buyers

For buyers in the food industry, it is crucial to have a system in place to verify whether a supplier complies with REACH and related legislation. The first step is to request written confirmation of the substance’s registration (the REACH registration number) or proof of exemption from registration. For food additives, it should be clearly stated whether the substance falls under the exemption pursuant to Article 2(7)(b) of REACH and for which specific purposes it is intended. It is also necessary to check whether the supplier provides a valid safety data sheet (SDS) for non-food applications, if applicable.

Other important points include verifying whether the substance is not listed on the Substances of Very High Concern (SVHC) list under REACH, and whether the supplier complies with the requirements of the CLP Regulation (classification, labelling and packaging). For foreign suppliers, it is necessary to verify whether they have an appointed representative in the EU who is responsible for fulfilling REACH obligations. A practical tool is also checking quality certificates (e.g. ISO 22000 for food safety) or audits conducted by independent bodies, which can confirm compliance with legislation.

SDS for Food Additives: Specifics and Common Mistakes

Safety Data Sheets (SDS) for food additives have their own specifics, which arise from their dual nature – as raw materials for the food industry and for industrial applications. If a substance is intended exclusively for food purposes, an SDS may not be required, but in practice, suppliers often provide it to facilitate communication with customers. In such cases, the SDS must clearly state that the substance is intended for food use only and that it meets the requirements of food legislation. Missing or unclear information can lead to misunderstandings and delays in the supply chain.

A common mistake is the inconsistency between the classification under CLP and the information in the SDS. For example, a substance classified as irritating to the eyes must have this information stated both on the packaging label and in the relevant SDS section. Another issue is insufficient updating of the SDS – if there is a change in the classification of the substance or new scientific findings about its properties, the SDS must be updated within 3 months. For buyers, it is important to regularly check whether they have the latest version of the SDS and to require confirmation of its current status from the supplier.

Unsure about the documentation for your raw materials?

GCG Group provides complete safety and technical documentation for every food additive supplied, including SDS and certificates of conformity. Our experts will advise you on assessing legislative requirements and selecting suitable alternatives if needed. Contact us – or browse our catalog of over 1,300 products right away.