European ban on smoke flavourings step in the right direction

Last spring, a majority of Member States agreed on European Commission proposals to withdraw the safety approval of eight smoke flavourings that are widely used in food and beverages. The decision entered into force on 1st July, confirming that the eight flavourings will be definitely banned from the EU market after transition periods ranging from two to five years.  

Smoke flavourings, which are made synthetically or by condensing real smoke, are often used to add a smoky flavour to food without the need for traditional smoking. Although these flavourings are widely used in various food products, there has been growing concern about the potential risks that they pose for the health of consumers. foodwatch welcomes the decision to ban these substances.  

Six of the eight flavourings in question can damage human DNA

According to the European Food Safety Authority (EFSA), six of the eight flavourings in question and that manufacturers currently use in smoked fish, meat, crisps, cheese and other products, contain substances that can damage human DNA, potentially causing cancer. For two of the eight flavourings, EFSA cannot rule out the possibility that they contain mutagenic components.  

In recent years, EFSA has conducted several studies on the effects of smoke flavourings. The results indicated possible adverse effects, including increased risks of cancer and other chronic diseases. In particular, the presence of polycyclic aromatic hydrocarbons (PAHs) in some smoke flavourings has raised serious concerns.  

PAHs are known carcinogens produced by the incomplete combustion of organic matter. Even when traditional smoking is used, the so-called PAHs can end up on, and possibly in, food. Therefore, this practice is also of concern for foodwatch. 

Transparency needed for consumers 

Today, it is impossible for consumers to tell which specific smoke flavouring has been used by the manufacturer in their food products. Even those carefully analysing the ingredients’ list will be left clueless, with the sole mention of 'smoke flavouring' on the label. For foodwatch, this is not acceptable and needs to change to guarantee the implementation of the right to know and allow consumers to make informed choices. 

The bigger picture on food additives: the need for a more efficient and protective system 

It is positive that EFSA and the European Commission have used a precautionary approach in assessing the smoke flavourings in question. Because on the one hand, EFSA identified genotoxicity concerns for six substances, and on the other hand it could not rule out health concerns for the remaining two that the European Commission decided to propose to ban them. 

As a reminder, the precautionary principle is a guiding principle of European Unions’ treaties and of the regulations on food. It foresees that in the case of scientific uncertainties about potential adverse effects of e.g. a substance, authorities can take regulatory action to prevent harm. 

foodwatch would like to see such a precautionary approach applied more often in the current operation of the authorisation system for flavourings and additives that are widely used in our food.  

In Europe there are currently 338 approved additives - each assigned a E number – which can legally be used in food. Around fifty additives are permitted in organic products, including the controversial nitrites and nitrates added to charcuterie. According to foodwatch, 338 is too many. This is due in part to the current (re-)authorisation system, which has numerous loopholes.  

• Firstly, the regulatory studies which provide the evidence around an additive. These are often provided by the industry themselves and can ignore important health endpoints and/or leave uncertainty concerning the risk of the exposure for the consumer. Due to lack of resources in the regulatory authorities (EFSA), the process can also take a long time, meaning that current authorisations are not always based on the latest scientific evidence and new scientific findings of concern may take years to trigger a new assessment.  
• Secondly, additives are currently assessed on a substance-by-substance basis without accounting for the reality of the consumers’ combined exposures in food products (because we are never exposed to one additive at the time). Usually more than one additive is present in a food product, and they can interfere with each other - this is called cocktail effect. The cocktail effect however is not currently accounted for in their regulatory assessment. This means that even if an additive on its own is deemed safe by EFSA, there is no safety assessment on the multiple types of additives we may be consuming throughout the day. Take the average ready-made meals, sauces, biscuits, sweets, soft drinks - these products can easily contain more than 10 ‘E’ numbers.  
• Thirdly, there is the problem of labelling. We as consumers may mistakenly think that every additive will be named using its ‘E’ number. Wrong. European legislation allows for companies to list either the ‘E’ number or the name of the additive. Additive E392 is usually listed as Rosemary Extract – it sounds very natural, as does E150d, Caramel colouring, often just listed as Ammonium sulphite caramel. As consumers we have a right to know what we are eating and not be misled. This is not the case around additives.  

Finally, several additives are controversial and new scientific research is coming out all the time. However, they are not immediately banned and in fact the process can take many years. For example:  

• The sweetener Aspartame (E951) is widely used in drinks such as Coca-Cola Zero and in chewing gum. But it is possibly carcinogenic according to the World Health Organisation’s International Agency for Research on Cancer (WHO’s IARC) which came out in July 2023. One year on, the companies can still use Aspartame in their products.  

• Preservatives nitrites and nitrates (E249 - E252) are often added in ham and meat products in order to maintain the pink/red appearance of the meat products. The food industry clearly prefers this over the natural colour of meat which would be grey or brown. But these additives are associated with a scientifically proven risk of (intestinal) cancer. So, this not only misleads consumers, but it may also cause serious harm!  

Yet these substances are still allowed in our food and this needs to change! 

Ban, downgrade, mention 

It is high time to clean up our food! That is why foodwatch demands a ban on all the food additives that are potentially harmful to human health, unnecessary or misleading to consumers. Because insufficient research has been done on the possible cocktail or cumulative effects of additives, foodwatch advocates minimal use and approval of additives.  

There are three steps needed - which are necessary but may not even be sufficient - to achieve an improved approach to additives in the EU:  

• Immediately ban the most dubious additives based on the precautionary principle. 
• Reduce the total amount of permitted additives to minimise the possible cocktail effect.

• Ensure that additives are labelled in a way that consumers can identify them. The correct E-number as well as the name of the substance should always be stated in the ingredients list.