Conflicting Approaches on Food Safety: US vs EU

Do Americans Have a Higher Tolerance for Pesticides


Conflicting Approaches on Food Safety: US vs EU

Policy approaches regarding food safety in the US and the EU are dramatically different. In the European Union (EU), their principal is straight forward: If there is substantial evidence of danger to human/environmental health, protective action is taken, despite scientific uncertainty. In the United States (US), scientific proof of harm to human/environmental health must be demonstrated before action is taken. Our question is this: Should additives be innocent until proven guilty?

European regulations against additives in foods and chemical residues are generally more strict than in the US, due to their precautionary approach. As a result, there are many chemicals that are deemed as unsafe and banned in the EU, but approved and distributed in the US. For example, artificial dyes in food products have been banned from the market in Norway and Austria due to health concerns. Popular food dyes, such as Yellow Dye No. 5, have been linked to problems in children including: allergies, increased aggressiveness, and learning impairments. Due to Europe’s stricter regulations, foods containing these additives were taken off the shelves following the risks outlined in only a handful of studies on their potential negative health effects. However, in the US, products that contain the same coloring agents are considered “safe” because of the inconsistent and/or lack of studies, and are allowed to be sold in the market.

Another example is Brominated Vegetable Oil (BVO), which acts as an emulsifier in soda and sports drinks. BVO contains bromine, an element found in brominated flame retardants. According to the United States Food and Drug Administration (USFDA), BVO has been sitting on a list of food additives “permitted on an interim basis pending further study” for decades. Like many chemicals in foods, BVO was placed in “regulatory limbo” and is deemed as safe until further notice. Many studies have concluded that bromine disrupts normal hormone function, brain development, thyroid function, fertility, and can even increase one's risk of cancer. The chemical has been banned in more than 100 different countries including almost all of Europe, but is still used in the US’s food supply.

Although the EU has a safer and more cautious approach, they have their flaws in their guidelines and regulations as well. Contaminants such as heavy metals are substances that have not been intentionally added to food, but are present in food as a result of various reasons. This could be production, packaging, transport or holding. Since contamination has a negative impact on the quality of food, the EU’s legislation set specific levels of contamination to be legally permitted. For example, arsenic is a heavy metal present in drinking water, grain-based products, and seafood that have been found to have carcinogenic properties and put humans at risk for different forms of diseases and abnormalities. While there is strict regulation around arsenic in the water supply in the EU, there are significantly less regulations on arsenic levels in foods. In the US, there is no standard for arsenic or other heavy metals in food, leaving the EU to remain the most strict regulatory system.

There are many more chemicals that are both intentionally and unintentionally found in foods that are allowed to be consumed in one part of the world, but are banned in others. The EU and the US authorities have simply reached different conclusions about food safety, based on the same amount of evidence and research. I don't know about you, but it makes me feel uneasy that there is no scientific or regulatory consensus when it comes to the agricultural and food products that we consume. So what does this mean for us, the consumers? We are expected to comply with these differentiated ways of approaching the chemicals added in our food, and found in our food, depending on where we find ourselves living in the world.