Request for Data: Food Additives and Flavourings

To comply with Commission Recommendation (EU) 2023/965 of 12 May 2023, Portugal must, like other Member States, classify and define the priority for monitoring the consumption of food additives and flavourings on an annual basis.

According to the Recommendation, the first classification and priority setting for food additives and flavourings took place by 30 September 2025.

In parallel, the European Commission defined a pilot study to be carried out by all Member States, with the aim of implementing working methods and strengthening collaboration between all entities involved in the process of collecting data on the occurrence, use, and presence or absence of food additives and flavourings. In 2024, the proposed list included the additives Green S (E142), Tartrazine (E102), Ponceau 4R (E124), and the flavourings Caffeine and Pulegone; and in 2025 the additives BHT (E321) and Sorbates (E200–202) and the flavourings Coumarin, Hydroxycinnamic Acid and Theobromine. The additives and flavourings selected for both years of the pilot study were defined by the EC based on the lists of five additives and five flavourings proposed by all Member States and by EFSA.

The data obtained in 2024 were reported to EFSA in June 2025, while the data for 2025 will be reported by June 2026.

From 2026 onwards, Member States must annually update the classification and priority setting, taking into account the results of the previous year’s monitoring and the new risk assessments published by the European Food Safety Authority (EFSA).

This prioritisation forms the basis for the development of a multiannual control plan, covering at least three years and listing the food additives and flavourings to be monitored each year.

This work includes the collection of data such as actual use levels, analytical data and presence/absence information, as well as the decision on which food categories should be monitored for the occurrence of food additives or flavourings, taking into account:

  • the food categories in which the presence of a food additive or flavouring is expected;
  • the food categories that are presumed to contribute significantly to the consumption of food additives and flavourings across the population or among specific age groups;
  • the main brands consumed;
  • the food items that may contribute to the intake of the substances under study/selected, from sources other than the use of food additives or flavourings.

Consequently, Member States must provide the European Food Safety Authority (EFSA) with the data collected each year, in the electronic format defined by EFSA.

They must also report annually to EFSA and the Commission the results of the prioritisation, the multiannual control plan, the methodology applied and whether any unauthorised uses were identified.

Prioritisation of Food Additives in Portugal

The prioritisation of food additives for the 2026–2028 multiannual monitoring plan will be based on the results of the dietary intake assessment carried out by INSA between 2024 and 2026, using the Portuguese system for monitoring food additive intake (MONITADITIVOS). It will also take into account Commission Recommendation (EU) 2023/965, which sets out the methodology for monitoring food additives and identifies high-priority substances, as well as the respective food categories.

The monitoring system estimates daily intake of food additives by combining population dietary consumption data with information on their concentration (maximum use levels — MULs) in each food category. This approach allows for an assessment of the potential risk associated with additive intake by comparing it with the Acceptable Daily Intake (ADI), thereby representing a worst-case scenario. The collection of actual use and/or occurrence data subsequently allows refinement of the estimates for the additives that exceeded or may exceed the ADI in the previous step, in which the MULs were considered.

In this context, the assessment of food additive intake carried out in 2024 among adolescents aged 11 to 17 years living in mainland Portugal was used to define the priorities for 2026. This age group was considered the highest-risk scenario, as adolescents tend to consume larger quantities of food in relation to their body weight.

Given the impracticality of assessing the entire population — as it is costly, time-consuming and constrained by limited resources — the study was initiated using this group as a reference case.

Recomendação (UE) 2023/965 da Comissão, de 12 de Maio de 2023 relativa à metodologia para o controlo do consumo de aditivos alimentares e aromas alimentares: https://eur-lex.europa.eu/legal-content/PT/TXT/PDF/?uri=CELEX:32023H0965