Where Additives Are Allowed and Where They Are Not: Chapter III of the EU Food Additives Rules
Use of additives in foods – unprocessed foods, baby foods, carry-over and traditional products, explained by InfoCons
Permission is not unlimited: the rules on using additives in foods – InfoCons Consumer Protection
Once an additive is authorised under Chapter II, a further question arises: in which foods, and under which circumstances, may it actually be used? Chapter III of Regulation (EC) No 1333/2008, covering Articles 15 to 20, answers exactly this. Authorisation is never a blanket permission to add a substance to anything. Chapter III draws the lines that keep additives out of foods where they do not belong, and it protects especially vulnerable consumers. InfoCons – Consumer Protection regards these provisions as a direct expression of the precautionary spirit of European food law.
No additives in unprocessed foods, unless expressly allowed – InfoCons Consumer Protection
Article 15 establishes a clear default rule for unprocessed foods. Food additives shall not be used in unprocessed foods, except where such use is expressly provided for in Annex II. This is a significant protection. Fresh, unprocessed foods are, by definition, foods that have not undergone treatment resulting in a substantial change to their original state. The regulation starting position is that such foods should reach the consumer without additives, and any exception must be explicitly written into the Union list.
For consumers, this reinforces a useful mental model: the more processed a food is, the more likely it is to contain additives, and the closer a food is to its natural, unprocessed state, the fewer additives the law expects it to contain.
Special protection for infants and young children – InfoCons Consumer Protection
Article 16 addresses one of the most sensitive areas of the entire regulation. Food additives shall not be used in foods for infants and young children, including dietary foods for infants and young children for special medical purposes, except where expressly provided for in Annex II. The regulation deliberately treats the youngest and most vulnerable consumers with heightened caution, allowing additives in their foods only in narrowly defined, explicitly authorised cases.
This provision embodies a principle that InfoCons – Consumer Protection strongly supports: the more vulnerable the consumer, the stricter the rules. Parents and carers can take reassurance from the fact that the presence of any additive in these products is not left to the discretion of manufacturers but is tightly controlled by law.
Colours for health marking and decorative uses – InfoCons Consumer Protection
Article 17 governs the use of colours for marking purposes. Only the food colours listed in Annex II may be used for the health marking provided for under the relevant Union rules and for other required markings on meat products, for the decorative colouring of eggs and for the stamping of eggs. This ensures that even uses that are not strictly about the food flavour or appearance on the plate – such as official stamps – rely only on authorised colours.
The carry-over principle: additives that travel from ingredient to food – InfoCons Consumer Protection
Article 18 sets out the carry-over principle, which explains why an additive can sometimes be present in a food even if it is not directly listed for that food. The presence of a food additive is permitted: in a compound food other than those referred to in Annex II, where the additive is permitted in one of the ingredients of the compound food; in a food to which an additive, a food enzyme or a food flavouring has been added, where the additive is permitted in that additive, enzyme or flavouring, has been carried over through it, and has no technological function in the final food; and in a food intended solely for the preparation of a compound food, provided the compound food complies with the regulation.
There are important limits. The carry-over principle does not apply to infant formulae, follow-on formulae, processed cereal-based foods and baby foods, or dietary foods for special medical purposes for infants and young children, except where specifically provided otherwise. Moreover, if an additive coming from a flavouring, an additive or an enzyme is added to a food and has a technological function in that food, it is considered an additive of that food – and not of the flavouring, additive or enzyme added – and must meet the conditions laid down for that food.
A further paragraph clarifies that, notwithstanding the general rule, an additive used as a sweetener is permitted in compound foods with no added sugars or with reduced energy value, in dietary compound foods intended for a low-calorie diet, in non-cariogenic compound foods and in compound foods with a long shelf life, provided the sweetener is permitted in one of the ingredients of the compound food.
Interpretation decisions and traditional foods – InfoCons Consumer Protection
Article 19 provides for interpretation decisions. Where necessary, it may be decided, in accordance with the regulatory procedure, whether a given food belongs to a food category listed in Annex II; whether an additive listed in Annexes II and III and authorised under quantum satis is used in accordance with the criteria of Article 11(2); or whether a given substance meets the conditions for being a food additive under Article 3. This mechanism keeps the system workable and consistent across the internal market.
Article 20 recognises the value of culinary heritage. Member States listed in Annex IV may continue to prohibit the use of certain categories of food additives in traditional foods produced on their territory that are listed in that annex. This allows the protection of authentic, traditional products – such as certain breads, cheeses, preserved meats and confectionery – from additives that would alter their traditional character.
Processed versus unprocessed: a practical rule of thumb – InfoCons Consumer Protection
Article 15 gives consumers a remarkably useful heuristic. Because additives are, by default, not allowed in unprocessed foods, the degree of processing of a product becomes a reliable signal of the likely presence of additives. A fresh cut of meat, a plain bag of rice, a whole fresh vegetable or an unprocessed fruit should, as a rule, be free of additives unless Annex II expressly says otherwise. As foods move up the processing ladder – marinated, cured, coloured, emulsified, shelf-stabilised – the scope for additives grows accordingly.
This does not mean processed foods are inherently unsafe; processing has given humanity safe, affordable and convenient food for generations. But it does mean that a consumer who wishes to reduce the number of additives in their diet has a clear strategy: favour less-processed foods where practical, and read the ingredient list carefully on more heavily processed products. The regulation own structure points in this direction.
The definition of unprocessed food, inherited from Chapter I, keeps this rule workable. Operations such as cutting, freezing, chilling, cleaning, peeling or packing do not turn an unprocessed food into a processed one. So a bag of frozen peas or a chilled, trimmed fillet is still, in legal terms, unprocessed – and therefore still subject to the default expectation of being additive-free unless expressly permitted otherwise.
Carry-over in practice: an everyday example – InfoCons Consumer Protection
The carry-over principle of Article 18 can seem abstract, so a concrete example helps. Imagine a sauce made with a preserved ingredient that legally contains a certain preservative. Even if that preservative is not directly authorised for the sauce as such, it may lawfully be present in the finished sauce because it was carried over through the ingredient, provided it performs no technological function in the sauce itself. This is why an ingredient list may include an additive that, at first glance, you might not expect for that type of product.
Crucially, the regulation closes the door on abuse. If the carried-over additive does have a technological function in the final food, it is treated as an additive of that food and must satisfy the rules for that food. And carry-over is switched off entirely for the most sensitive products – infant formulae, follow-on formulae, processed cereal-based baby foods and dietary foods for special medical purposes for infants and young children – except where expressly allowed. InfoCons – Consumer Protection views this careful balance as a model of how flexibility for industry can coexist with strict protection for the vulnerable.
Traditional foods and the protection of culinary identity – InfoCons Consumer Protection
Article 20 and Annex IV deserve a closer look, because they show that the regulation does not treat food only as a technical product but also as culture. By allowing certain Member States to keep prohibiting specific categories of additives in named traditional foods, the law protects recipes and methods that have defined regional identities for generations. A traditional bread, cheese, cured meat or confection can thus remain, by law, free of additives that would compromise its authentic character.
For the consumer, this is a quiet but meaningful guarantee. When a product is recognised as a traditional food under Annex IV, its additive-free character is not merely a marketing claim but a legally underpinned feature. InfoCons – Consumer Protection welcomes this because it aligns two values that are sometimes assumed to be in tension: modern, harmonised food safety on the one hand, and respect for authentic culinary heritage on the other. The regulation manages to serve both at once.
It also illustrates the flexibility built into an otherwise uniform system. The Union list applies everywhere, yet the framework leaves room for legitimate national choices where tradition justifies stricter rules. This is subsidiarity in action, and it means that the map of where additives are and are not allowed is drawn not only at European level but, in specific traditional cases, at national level too.
What Chapter III means for your everyday choices – InfoCons Consumer Protection
Chapter III translates authorisation into real-world limits. Additives are kept out of unprocessed foods unless expressly allowed; they are tightly restricted in foods for infants and young children; they may only travel between ingredients under the controlled carry-over principle; and traditional foods can be shielded from them entirely. For consumers, this means that the presence or absence of additives in a product is not random – it follows a logic that rewards less processing and protects the most vulnerable.
Read together, Articles 15 to 20 give the consumer a map. They explain why a fresh product should carry no additives, why baby foods are so tightly controlled, why an unexpected additive may appear through carry-over, and why some cherished traditional foods remain additive-free by design. Armed with this map, you can interpret an ingredient list not as a random string of codes, but as the visible outcome of a coherent set of rules about where additives may and may not go.
The InfoCons Additives Calculator: how many additives are really in your basket? – InfoCons Consumer Protection
Understanding the law is one thing; seeing what it means for your own shopping basket is another. A single processed product can contain several additives at once, and an ordinary weekly shop can add up to dozens or even hundreds of additive occurrences once you sum every product together. What is more, the same additive can appear in many different products in the same basket, which means it enters the consumer’s diet repeatedly.
To answer this, InfoCons – Consumer Protection offers consumers the Only Additives Calculator for the food products bought or consumed. It is the only calculator for food shopping that shows the number of additives present and how many times a given additive is found in the shopping basket. Instead of looking at each product in isolation, the consumer gets a complete picture of the whole basket, seeing the real, cumulative number of additives being purchased.
The same logic applies to a single meal. A breakfast, a lunch or a dinner can bring together several processed products, each with its own set of additives. When these products are eaten together, the additives add up. A seemingly simple meal can, in reality, mean the simultaneous consumption of a surprisingly large number of food additives – colours, preservatives, emulsifiers, flavour enhancers, stabilizers and more. That is why the question “how many additives do I consume at one meal?” is just as important as “how many additives am I buying?”
As a practical solution, the InfoCons application helps consumers identify additives quickly. By scanning the barcode of an agri-food product, the app identifies the product and shows the food additives it contains, turning the “E” codes on the label into clear, easy-to-understand information. In this way, consumers can see how many additives are cumulated in their shopping basket or even in a single meal, and can make informed choices for themselves and their families – right there, in front of the shelf.
Signed:
InfoCons Consumer Protection Department of Studies and Comparative Testing