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Are Direct Food Additives Permitted for Use in Food-Contact Applications?

May 1, 2012
Question 

If a chemical substance appears on FDA's EAFUS list (i.e, approved food additives, such as sodium chloride), does it automatically imply that this substance is cleared by the FDA for use in the manufacture of indirect food contact materials such as non-stick food contact coating or food packaging?

Answer 

The Everything Added to Food in the United States (EAFUS) list that you refer to contains ingredients added directly to food that the Food and Drug Administration (FDA) has either cleared as food additives, color additives, or are accepted by FDA as GRAS. Despite its title, the list does not include "everything" added to food in the U.S. It only includes indirect food additives if they're also cleared as direct additives, secondary direct additives, or are listed by FDA as GRAS. In addition, companies can rely on self-determinations of GRAS for direct food additives, which would not be listed in EAFUS either. To determine if a substance cleared by FDA as a food additive can be used in a specific food-contact application, you would need to consider whether it is the subject of an applicable food additive regulation, food-contact notification, or otherwise permitted for use with food. In addition, you need to make sure any end quantitative limitations and end-test requirements are met.