You’re perusing the bread section in a supermarket in the United Kingdom. You pick out your favorite brand and glance at the ingredients list.
A short time later, you're in a grocery store in the United States and, once again, you find yourself in the bread aisle. You pick the same bread from the same brand, but the list of ingredients is different.
Why aren't the ingredients the same? And what does this mean for your health? Strap in, and we’ll unravel it all.
Along the way, we’ll meet chlorinated chicken, banned food colorings, political lobbying, sheep lungs, and much, much more. It’s quite a ride.
Why the difference?
One of the main reasons that your two loaves have different ingredients is that rules about food additives are generally more strict in the European Union than in the U.S.
And as the U.K. transitions away from the E.U., we might slowly see differences between foods in these areas. More on that later.
Historically, the U.S. Food and Drug Administration (FDA) tended to wait until an additive was flagged as dangerous before acting.
By contrast, the E.U.'s equivalent, the European Food Safety Authority (EFSA), has always been more proactive.
But this may be slowly changing.
In 2011, the FDA brought in the Food Safety Modernization Act. These changes encourage them to get more involved in determining what should be off-limits.
However, there’s a substantial loophole in FDA guidelines that food manufacturers can sneak through.
Compounds that are generally recognized as safe (GRAS) don’t need to go through the official approval process.
This loophole was first created in 1958 so manufacturers didn’t have to seek approval for common ingredients like vinegar and vegetable oil.
That makes sense, but over the years, this loophole has been stretched wide.
The FDA relies on food manufacturers to inform them about GRAS ingredients. And food manufacturers aren’t necessarily keen on getting the FDA involved.
Some experts estimate that there are around 1,000 of these largely untested ingredients in U.S. foods.
And if they’re untested, no one knows what their health effects might be.
US ingredients banned in the EU
Due to the historical differences between U.S. and E.U. legislation and the GRAS loophole, U.S. foods contain many chemicals that aren’t allowed in Europe.
We’ll take a look at some of these.
In the U.S., manufacturers use potassium bromate in bread products. It helps strengthen the dough and makes it rise higher.
The International Agency for Research on Cancer classes it as a 2B carcinogen, which means that it’s “possibly carcinogenic to humans.”
They explain that potassium bromate causes cancer in mice, rats, and hamsters — but there’s not enough evidence from human studies to know whether it causes cancer in us.
To be safe, it’s banned in many places, including the E.U., Argentina, Nigeria, South Korea, India, and China.
The FDA has “urged” manufacturers not to use potassium bromate. But the chemical is still approved for use.
Though it sounds like a conjurer’s spell, azodicarbonamide is also used in baking. It makes dough tougher and bread whiter.
The chemical also appears in a range of other items, like yoga mats.
In the U.S., azodicarbonamide enjoys GRAS status. But due to public pressure, some restaurants have stopped using it.
When azodicarbonamide breaks down, it can form semicarbazide.
Early animal studies have shown that this chemical might slightly increase cancer risk, so the E.U. has erred on the side of caution.
Later studies, however, have shown that the cancer risk is likely very small.
Butylated hydroxyanisole (BHA) is a flavor enhancer and food preservative that’s banned in the E.U.
In the U.S., manufacturers add it to a range of foods, including fast foods, cereals, drink mixes, gum, and snacks. It’s also in plastics, rubber, cosmetics, and food packaging.
The FDA considers this chemical to be GRAS. But the National Toxicology Program at the National Institutes of Health (NIH) explains that BHA is “reasonably anticipated to be a human carcinogen.”
BHA is used in the E.U. Tighter restrictions were in place — though since 2012, these have loosened.
Brominated vegetable oil
Brominated vegetable oil (BVO) appears in some sodas in the U.S. Manufacturers use it to prevent separation in citrus-flavored drinks.
Although BVO is FDA-approved, some manufacturers have stopped adding it to some of their drinks due to public pressure.
As the name suggests, BVO contains the chemical element bromine. If you consume a lot of products that contain BVO, bromine can build up in your body and cause a condition called bromism.
This health condition is mercifully rare, but it can cause severe neurological problems and affect your gut and skin.
According to the Center for Science in the Public Interest, safety concerns about BVO arose in 1970 after the publication of a Canadian study in rats.
In response, the FDA took BVO off the GRAS list but said manufacturers could still use it "in the interim" while researchers carried out additional studies.
Scientists have found that BVO can leave residues in the body.
Also, animal studies have shown that it can pass to offspring through milk, leading to heart and liver problems and developmental changes. Of course, animal studies don’t necessarily reflect what happens in humans.
Still, half a century has passed since people first raised concerns. There’s been little further research, and BVO is still on the interim list.
In general, food manufacturers are more likely to add synthetic colorants to foods in the U.S. than the U.K.
For instance, in the U.S., the McDonald’s strawberry sundae gets its redness from the mysteriously named red 40. In the U.K., it gets its color from strawberries.
Similarly, Fanta in the U.S. gets its electric hue from the colorants red 40 and yellow 6. In the U.K., the color comes from pumpkin and carrot extracts.
Manufacturers can use yellow 6 (also called sunset yellow FCF) in the E.U. But they have to acknowledge on labels that the product “may have an adverse effect on activity and attention in children.”
In the U.S., no warnings are necessary.
Meanwhile, in March 2022, the E.U. banned a food colorant called titanium dioxide. The move came after studies showed that it might damage DNA. It’s still approved for use in the U.S.
Incredibly, the FDA doesn’t require manufacturers to test food colorants for developmental neurotoxocity — whether the chemicals can interfere with the developing brain or nerves during pregnancy or childhood.
According to Bernard Weiss, a professor of environmental medicine at the University of Rochester, “Their inaction amounts to approval of an ongoing experiment with children.”
And a damning report from the Center for Science in the Public Interest concludes that “Studies of the nine dyes currently approved by the FDA suggest, if not prove, that most of the dyes cause health problems, including cancer, hypersensitivity, or neurotoxicity.”
Chemicals on the farm
Setting aside preservatives, colorants, and other additives for the moment, some compounds enter food through farming or meat processing.
And some of these practices are banned outside of the U.S. We’ll cover a few below.
Ractopamine is a chemical added to pig and cattle feed to boost muscle growth. This means that farmers can breed bigger animals with lower feed costs.
Globally, most governments of nations and other jurisdictions — more than 160 — have banned the chemical. Among them are the E.U., China, Taiwan, and Russia.
In 2009, the EFSA reviewed the research and concluded that there wasn’t enough evidence to show if ractopamine was safe.
Scientists have only conducted one study in humans, with just six participants, who were healthy men. The researchers gave them steadily increasing doses of ractopamine.
After the highest doses, the participants’ heart rates increased. One had to stop his involvement early because of “adverse cardiac events.”
So, despite a lack of more general evidence, the EFSA has raised concerns about this chemical's potential effects in people with cardiovascular disease.
Recombinant bovine growth hormone
Farmers use recombinant bovine growth hormone (rBGH) to boost milk production in cows. It’s also called recombinant bovine somatotropin and artificial growth hormone.
rBGH is still used in the U.S., but it's banned in the E.U. and several other countries.
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Overall, the evidence that these chemicals harm humans is scant — but there’s also not enough evidence that they're safe.
Plus, according to the EFSA, these hormones might cause additional suffering in farm animals and impact the environment — two more excellent reasons to reduce their use.
In the U.S., poultry farmers clean poultry with chlorine to kill off microorganisms that might cause illness.
This is banned in the E.U. — but not for the reasons you might expect.
The EFSA has concluded that poultry cleaned with chlorine is not dangerous to humans. And in the E.U., it’s perfectly legal to sell salad cleaned in the same way.
Instead, the European Commission is concerned that chlorine rinses are a way to sidestep animal welfare standards earlier in the process.
Crowded, dirty abattoirs and cramped living spaces are common in the U.S. They're also breeding grounds for bacteria.
The E.U. would prefer that animals had better living conditions throughout their lives. This way, there'd be no need for a chlorine wash after death.
Many of you will be aware of antibiotic resistance. But fewer people realize that farming uses the majority of antibiotics.
Farmers use them to prevent infections in crowded conditions and to boost the growth of livestock. The World Health Organization (WHO) has urged farmers to stop.
But in the U.S., farmers use five times more antibiotics than they do in the U.K.
How much antibiotic then makes it onto your plate? The amount is likely low, and the U.S. Department of Agriculture closely monitors it.
Antibiotic residues are still a threat to health, though.
Beyond encouraging antibiotic resistance, they can impact the gut microbiome and damage the liver, kidney, and bone marrow. Antibiotic residues may also be carcinogenic and cause reproductive disorders.
Pesticides are an important part of farming — they stop pests from eating crops before we do.
Although you won’t see them on ingredient lists, these chemicals often make it into your dinner.
So, regional and national governments have to weigh up the benefits and risks. And inevitably, some pesticides get banned.
According to one study, in 2016, the U.S. was still using 72 pesticides that were banned in the E.U.
The study's authors explain that the body responsible for controlling pesticide use in the U.S. — the Environmental Protection Agency (EPA) — mostly relies on the farming industry's decisions.
And in general, the U.S. has much weaker standards when it comes to pesticide residues in food. A recent report from Pesticide Action Network UK gives these examples:
In the U.S., grapes can be sold with 1,000 times more propargite than is legal in the U.K. According to the EPA, this chemical can cause skin and eye irritation and is a “probable human carcinogen.”
In the U.S., soy can have 7.5 times as much tetraconazole than is legal in the U.K. The EPA classifies this fungicide as “likely to be carcinogenic to humans.”
And apples in the U.S. can contain 400 times the amount of malathion than is legal in the U.K. The International Agency for Research on Cancer concluded that malathion is “probably carcinogenic to humans.”
The effects of pesticides on human health aren't fully fleshed out yet, but it’s becoming clearer that they can interfere with your gut microbiome.
Also, growing evidence suggests that they act as endocrine-disrupting chemicals, which can interfere with the delicate balance of hormones your body.
Legislators base their decisions about pesticide safety on studies, so understanding the long-term effects of daily exposure to these chemicals is an important and growing area of focus.
Meanwhile, the negative effects of pesticides on the environment are already well-documented. And what hurts the environment will inevitably harm humanity.
Are any EU foods banned in the US?
It isn’t a one-way street — some foods that are banned in the U.S. are legal in the E.U. The list is short but interesting.
Kinder Surprise eggs
These are hollow chocolate eggs, and each had a toy inside. In the 1990s, they were banned in the U.S. because the toy was considered a choking hazard.
But in 2018, the product was altered so the toy was no longer inside the chocolate. Now, thankfully for all Americans, they’re legal.
Haggis is an animal’s stomach filled with chopped sheep organs, herbs, and spices. Because it contains sheep’s lungs, imports were banned in the U.S. in 1971.
Given the ingredients, haggis may not be missed by many people in the U.S.
But if you're based in the U.S. and interested in trying this Scottish delicacy, there are companies that produce lung-free haggis. Phew.
These seemingly innocuous berries threatened the U.S. timber industry by spreading a fungus called white pine blister rust.
So, in 1911, the government banned people from growing, selling, or transporting blackcurrants.
The federal ban was lifted in the 1960s, but some states kept it.
Unpasteurized milk and cheese
Pasteurization kills off bacteria in milk. According to the FDA, unpasteurized, or raw, milk can contain Salmonella, E. coli, Listeria, Campylobacter, and other bugs that can cause food poisoning.
It's still legal in about half of the states to buy and sell raw milk.
But even in these states, it’s not legal to transport this milk over state lines packaged and ready to sell. You can transport it if the milk is going to be further processed.
Also, any cheese made from raw milk needs to be aged for at least 60 days under specific conditions to be sold legally.
What about sugar and calories?
Moving away from obscure-sounding chemicals, let's look at how the overall makeup of foods can differ between the U.S. and E.U.
We compared a few products that are sold in both places. Aside from the ingredients named above, the compositions of some products don't differ much.
But for others, particularly sodas, there’s a significant difference.
For instance, Fanta orange soda in the U.S. has about 44 calories per 100 milliliters. In the U.K., the same amount has 19 calories.
And the reason is clear: In the U.S., there are 12 grams of sugar per 100 ml, while on the other side of the Atlantic, there are “only” around 5 g per 100 ml.
That’s more than double the sugar in an already sugary drink.
Let’s look at children’s breakfast cereals as another example.
A study from 2019 compared more than 600 of these products from five countries — New Zealand, Australia, the U.K., Canada, and the U.S.
On average, the U.K.’s cereals had the least salt and sugar, and products in the U.S. had the most sugar.
The U.S. also had the most products that contained at least 20% sugar.
Worryingly, 18 of the 195 U.S. breakfast cereals tested — almost 1 in 10 products — were were at least 50% sugar.
Differences between the two countries also extend to restaurants. A study from 2018 compared 41,000 menu items from 42 large chain restaurants in the U.K. and 96 of these restaurants in the U.S.
On average, items on U.S. menus had more calories, sugar, fat, and saturated fat than their U.K. counterparts.
To be fair, the researchers also note: “As more than 95% of all items were considered to have high levels of at least one nutrient of public health concern in the U.S. and the U.K., improvements in restaurant menu items are needed in both countries.”
The role of food lobbying
When you walk into a grocery store, there’s often a huge range of products. What isn’t immediately clear is that only a handful of giant companies own them.
For instance, 93% of the sodas consumed in the U.S. and 73% of breakfast cereals are owned by just three companies.
Lots of popular products mean large profits. And large profits enable food companies to spend big on lobbying.
What is lobbying?
Lobbying is when an individual or group tries to convince the government to support a particular campaign or policy.
Lobbying serves an important role. But it means that food manufacturers with deep pockets who contribute to election campaigns have increased access to legislators.
In short, lobbyists for food manufacturers try to limit legislation that might hurt their employers' profits.
And they push for legislation that might boost their bottom lines.
The U.S. food industry has a particularly strong lobbying presence.
And the fact that companies spend millions of dollars on lobbying each year means that it must work — otherwise, they’d stop wasting their money.
Lobbying in action
A damning paper published in October 2022 shows that even the Academy of Nutrition and Dietetics (AND) isn’t immune to lobbyists.
With over 100,000 members, it's the largest organization of food and nutrition professionals.
The AND’s mission is “to accelerate improvements in global health and well-being through food and nutrition.”
But, according to the authors of the paper, they've received millions of dollars from big businesses and helped shape regulations to suit these companies’ bottom lines.
The AND even invested in companies that produce ultra-processed foods, which is clearly in direct opposition to their mission.
Not pulling any punches, Gary Ruskin, one of the paper’s authors and the executive director of U.S. Right to Know, said:
“The documents reveal a depressing chapter of corruption at this influential nutrition group. If we’re going to get healthier, live longer, and lower our astounding rates of obesity and diabetes, we’ve got to clean out the corruption at health groups like the [AND].”
The U.S. certainly isn’t the only country where huge food corporations have undue influence over food safety and legislation.
However, in the E.U. — but not the U.K. — lobbying is governed more tightly.
The take-home message is this: The food industry in the U.S. (and everywhere else on Earth) is massive. And the vast majority of the big players don’t care about your health.
It doesn't concern them whether added ingredients cause disease or not. Food giants put their profits above your health. Always.
A note on Brexit
For those living in the U.K., we mustn’t be too smug about our shorter ingredients lists.
Since leaving the E.U. and seeking to strengthen trade ties with the U.S. and other countries, we might soon see some of the dauntingly named chemicals in U.S. food make their way onto our plates.
As we put this article together in early 2023, the U.K. government is busy running through E.U. legislation and deciding which rules they’ll keep and which they’ll throw out.
The U.K. may axe as many as 2,400 E.U. laws, some of which include food safety laws.
Sadly, public health is not always the top priority of a government that receives significant cash donations from the food industry. Especially when they’re switching prime ministers every few weeks.
What’s the verdict?
Overall, the E.U. bans ingredients that it thinks might be dangerous, whereas the U.S. tends to wait and see.
Many of the banned ingredients in the E.U. aren’t proven to be deadly by any means — legislators there are just more cautious.
However, if an ingredient that might be mildly dangerous is eaten every single day alongside a bunch of other ingredients that might be dangerous, no one knows how it will affect our health.
And that’s the bottom line — we don’t really know what these common cocktails of chemicals do to human health.
So, what can you do about it?
Here at ZOE, no food is off the table. We encourage you to enjoy the foods you love.
However, when it comes to ultra-processed foods — which contain the highest levels of these difficult-to-spell ingredients — it’s best to enjoy them in moderation.
In general, it’s better to choose fresh, unprocessed, or minimally processed foods whenever possible.
Then, not only will you avoid the mystery chemicals, you’ll be getting more important nutrients, like fiber, and plant chemicals, like polyphenols.
Navigating food labels can be challenging, but as a general rule: If there’s a long list of ingredients you don’t recognize, it might be best to swap that product for a simpler alternative.
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