Key Regulatory Updates and Titanium Dioxide Substitutes
Key Regulatory Decisions on the Usage of Titanium Dioxide: EU, USA, and Canada
This ban only impacts markets in the EU, including imports and exports through EU countries, but has re-ignited regulatory dialogue worldwide.
Timeline Overview
The European Commission’s Ban
of Titanium Dioxide
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2016The European Food Safety Authority (EFSA) inconclusively evaluated titanium dioxide, E171, as a food additive citing more research was needed to determine its safe usage.
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2020The European Commission requests EFSA to re-evaluate Titanium Dioxide.
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2021“Taking into account all available scientific studies and data, the [European Food Safety Authority] panel concluded that titanium dioxide can no longer be considered safe as a food additive.”
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2022The European commission banned titanium dioxide, E171, as a food additive beginning with a six-month phase out period in February 2022-August 2022. After August 2022, a full ban on titanium dioxide in food and animal feed applies.
Here’s what’s happening in North America…
Health Canada Updates Statement Concluding Titanium Dioxide is Safe
In June 2022, Health Canada’s Food Directorate released an updated statement regarding the safety of titanium dioxide as a food additive. In summary, Health Canada maintains that no scientific evidence conclusively indicates human health concerns based on available data. While future updates may follow if new scientific information becomes available, no changes are currently being made. Titanium dioxide is currently permitted in Canada as a food additive.
United States FDA Does Not Plan to Ban Titanium Dioxide as a Food Additive
The FDA has not released any official statements following the European Commission’s ban. Without new scientific data indicating human health risks, comments from the FDA have not indicated any plans to ban titanium dioxide as a food additive.
The FDA’s stance on titanium dioxide overtly paints the picture of the different regulatory approaches out in the food and beverage landscape today. Europe takes a precautionary approach to additive rulings, meaning if evidence can’t establish safety, a ban is often advised. In contrast, the FDA in the United States heavily leans on evidence-based rulings, where the federal agency needs to be explicitly shown an additive’s harmful effect through robust scientific research. It’s an interesting duality. A less conservative guidance process could keep the door open for continued consumer/advocacy group scrutiny, as well as unprecedented legal action occurring in the United States right now with a multinational confection manufacturer—BUT we certainly hope not at the end of the day.
June 2022
As of June 2022, a new bill was introduced to the US Senate calling for the creation of a new FDA office to reassess food chemical safety, specifically citing ten ingredients for immediate reassessment including titanium dioxide. This national bill remains in committee and has not seen a vote yet.
August 2022
The FDA maintains titanium dioxide is safe for use when used in accordance with its usage guidance in not exceeding 1% of the finished product’s weight.
2023 State-Level Attacks
In 2023, several states including California, New York, and New Jersey introduced state-level bills to ban five ingredients including titanium dioxide. California Bill 418 was amended to remove titanium dioxide from its text and the amended version passed in California in September 2023. Titanium dioxide does, however, remain a focus of legislative discussion in several states and at a national level.
An excerpt from U.S. Senate Bill S.4316:
“(f) First Substances Subject To Reassessment. The first 10 substances or classes of substances by the Secretary under subsection (b) shall be the following:
- “(1) Perfluoroalkyl substances & polyfluoroalkyl substances
- “(2) Ortho-phthalatess
- “(3) The class of bisphenols
- “(4) Titanium dioxide
- “(5) Potassium bromate
- “(6) Perchlorate
- “(7) Butylated hydroxyanisole
- “(8) Butylated hydroxytoluene (BHT)
- “(9) Brominated vegetable oil (BVO)
- “(10) Propyl paraben
Consumer Perception of Titanium Dioxide Trends Downward
While titanium dioxide (TiO2) has been in the spotlight in North America since 2016, the scrutiny has never been broadcasted like it is today.
Negative consumer sentiment towards titanium dioxide continues to increase this year, most likely due to two widely broadcasted events…
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01.European Commission’s announcement to ban titanium dioxide
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02.A lawsuit in the US against leading confection manufacturer
% of consumers who avoid food, beverage, and pet products containing titanium dioxide due to safety concerns.
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33%
Early 2022
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48%
JULY 2022
Google searches asking “what foods have titanium
dioxide” have seen a
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+5000%
SINCE MID-JULY 2022
echoing the growing concern over the widely used food color indicated by Sensient’s Consumer Research.
Source: Sensient Consumer Research, 2022
Manufacturers Put in a Hard Position
The usage of the widely popular whitening color, titanium dioxide, has subsided due to ongoing controversy, especially in the last few years.
In response to the ongoing regulatory conversations, several brands have preemptively listed titanium dioxide on their no-no ingredient lists some time ago, including…
The controversy certainly places manufacturers in a tough position today, despite the FDA and Health Canada’s continued safety issuance of titanium dioxide. Unfortunately, the media seems to be escalating the topic into consumer’s everyday news feeds and channels. Big time newspapers such as The New York Times, The Washington Post, USA Today, etc., as well as major cable news outlets like Fox and CNN have also been reporting on the titanium dioxide contention.
Sensient supports manufacturers’ decisions either way, understanding both…
The use of the high-performing, cost-effective titanium dioxide color solution is fully compliant per FDA and Health Canada’s rulings.
The desire to substitute titanium dioxide with alternative market options like solutions from Sensient’s Avalanche™ portfolio.
Sensient’s AvalancheTM
Titanium Dioxide Replacement Portfolio
Avalanche™ is a portfolio of titanium dioxide substitutes designed for virtually any food, beverage, and pet/animal feed category. Whitening and opacifying solutions in the Avalanche™ portfolio have been developed to best match the performance of titanium dioxide to empower easy renovation and innovation for brands.
There are over twenty solutions in the Avalanche™ portfolio—its breadth of solutions is designed to fully encompass the diverse processing parameters and various color performance needs of all the categories in which titanium dioxide is or would be an ideal whitening or opacifying agent.
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AvalancheTM Fusion Xtra SOLUTIONS
Processing Parameter:
Low Heat/Low Water Activity
Performance Need:
Whiteness and/or Opacification
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AvalancheTM MB SOLUTIONS
Processing Parameter:
Heat & Extrusion Stability
Performance Need:
Whiteness and/or Opacification
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AvalancheTM HELIO SOLUTIONS
Processing Parameter:
High Heat Stability
Performance Need:
Opacification
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AvalancheTM ULTRA
SOLUTIONSProcessing Parameter:
High Water Activity
Performance Need:
Whiteness and/or Opacification
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AvalancheTM NEBULA
SOLUTIONSProcessing Parameter:
High Water Activity
Performance Need:
Cloud and/or Opacification
Hover over each sub-category icon for technical information on replacing titanium dioxide with alternatives like solutions from Sensient’s Avalanche™ portfolio.
CONFECTIONS
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GUMMY CANDY
AvalancheTM Fusion Xtra solutions enable gummy confection developers to overcome the yellowish-brown hues in gelatin bases, maintaining stability through mixing, depositing, and cooling process.
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CHEWING GUM
At low usage rates, AvalancheTM Fusion Xtra solutions provide bright white shades with minimal impact to texture for gum bases, maintaining stability under the heat conditions associated with steam cookers.
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HARD CANDY
AvalancheTM MB solutions provide hard boiled candy developers with a cloudy visual effect that survives the high processing temperatures without any impact to texture and taste due to its low usage rate.
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Panned Candy & Gum
AvalancheTM Fusion Xtra solutions available in powder and dispersion forms provide panned candy developers a smooth, consistent and high-performing coating system enabling brilliant whites at low usage rates.
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Compound Coatings
AvalancheTM Fusion Xtra solutions offer developers the brightest whites for enrobing, drizzling, etc. in confection applications with even color consistency, minimal impact to texture, and no bleeding.
PET & ANIMAL FEED
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Baked Treats
AvalancheTM MB solutions offer bake-stable, AAFCO-compliant whites for treat developers, serving as a primer solution allowing flavorful shades to shine in common mash bases.
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Extruded Treats and Kibble/Feed
AvalancheTM MB solutions provide developers stable whites under the harsh extrusion heat processing enabling visual consistency and flavorful hues batch-to-batch.
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Retort Canned Food
AvalancheTM Helio solutions are specifically formulated to survive the harsh retort process to provide opacity for canned pet food developers at low usage rates that don’t impact overall product taste and texture.
BAKING INGREDIENTS
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Frostings, Icings, Compound Coatings, Glazes, & Buttercreams
AvalancheTM Fusion Xtra solutions offer developers the brightest whites for topical baking applications with even color consistency and minimal impact to texture.
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Extruded Sprinkle Inclusions
AvalancheTM MB solutions are designed to withstand extrusion, serving as a priming solution to bring forth the bright colorful hues expected by consumers without any impact to the taste experience.
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Instant Pudding & Pie Mixes
AvalancheTM Nebula solutions enable clean label opacity and excellent solubility without impacting overall taste and texture due to low usage rates.
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Fillings & Custards
AvalancheTM Ultra solutions provide product developers with a high-performing opacity agent for high-water systems without impacting overall taste and texture due to low usage rates.
PLANT-BASED MEAT & DAIRY PRODUCTS
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Plant-Based Meat Analogues
AvalancheTM MB solution options are designed to whiten plant-based meat bases and withstand high-heat conditions like high-moisture extrusion or shear cell structure formation enabling developers to mimic the hues of animal pork, poultry, and seafood.
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Plant-Based Cheese
AvalancheTM MB solutions offer plant-based developers a clean-label heat- and water-stable whitening solution that does not interfere with thickeners or emulsifiers allowing developers to mimic the pure white shades and bright orange hues of dairy cheeses that consumers expect.
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Plant-Based Cheese Sauces
AvalancheTM Ultra solutions provide whitening and opacity under high water activity without negatively impacting the texture in plant-based cheese sauces.
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Plant-Based Ice Cream
AvalancheTM Ultra solution options are designed to whiten plant-based ice cream bases to overcome the undesirable beige hues associated with alternative milk bases without impact to texture and taste.
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Plant-Based Dairy Drinks
AvalancheTM Ultra solutions help developers overcome brown or green base notes from plant-based proteins in nondairy beverage applications while maintaining excellent water stability.
PANTRY & SNACKS
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Packaged Cookies & Snack Cakes
AvalancheTM Fusion Xtra solutions offer developers bright whites for cremes, coatings, icings, and/or frostings in packaged baked goods at low usage rates for minimal impact to mouthfeel and enhanced no-bleed stability.
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Soups
AvalancheTM Helio solutions give developers opacity and whitening that survives retort’s harsh heat environment at low usage rates.
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Instant Sauce Dry Mixes
AvalancheTM Fusion Xtra solutions offer opacity for dry mix sauce while ensuring solubility and suspension.
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RTE Sauces, Dressings, & Dips
AvalancheTM Ultra solutions enable stable, cloudy opacity without impact to viscosity.
BEVERAGES
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Carbonated & Still Drinks
AvalancheTM Nebula solutions offer beverage developers a cloud opacifier fully stable with full suspension in high water activity beverages without any impact to taste and texture. TTB-approved options available for alcoholic RTDs.
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Multi-Serve Powder Drink Mixes
AvalancheTM Nebula solutions exhibit full cloudy suspension for extended times upon high water content hydration.
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Single-Serve Powder Drink Stick
AvalancheTM Fusion Xtra solution options give developers a clean cloud solution free-from weighted agents enabling full and consistent incorporation during the mix process and quick solubility upon hydration.
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RTD Mixers
AvalancheTM Nebula solutions provide a clean cloud in high water matrixes with full shelf-life suspension.
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Syrups & Concentrates
AvalancheTM Nebula solution options survive the heat treatment in beverage syrup and concentrates enabling a clean cloud visual in the finished good to which the syrup is added.
The Avalanche portfolio are high-performing color solutions developed for success and outperform alternative market options especially single components like rice starch or calcium carbonate.
Sensient’s color experts can give personalized, real-time guidance on Avalanche solutions using our VIVID Platform
(Virtual Interactive Visualization & Ingredient Development)
