How Thousands of Untested Chemicals Enter Our Food Supply
America's food safety system has a dangerous blind spot that affects virtually every processed food on supermarket shelves.
You carefully check food labels, trying to avoid artificial ingredients and questionable additives. But what if I told you that thousands of chemicals in your food have never been properly evaluated for safety by the FDA?
What you'll learn in this article:
✔️ How food companies can legally add chemicals to food without FDA approval
✔️ Why the "Generally Recognized As Safe" (GRAS) system is a failure
✔️ Real examples of controversial ingredients currently in your food
✔️ Recent policy developments that could finally close this regulatory gap
✔️ Practical steps to protect yourself and your family
What Exactly Is the GRAS Loophole?
The "Generally Recognized As Safe" (GRAS) designation began with reasonable intentions in 1958. Originally, it was designed to exempt common ingredients with established safety records—things like salt, vinegar, and baking soda—from requiring formal FDA approval before use in foods.
But what started as a sensible exemption for truly common ingredients has morphed into something far more troubling.
Since the FDA implemented a voluntary notification system in 1997, food companies gained the ability to determine for themselves whether their new ingredients are "safe" without any obligation to inform federal regulators or the public. This self-determination process has effectively created a regulatory environment where companies can "self-GRAS" nearly any substance they wish to add to foods.
"For far too long, ingredient manufacturers and sponsors have exploited a loophole that has allowed new ingredients and chemicals, often with unknown safety data, to be introduced into the U.S. food supply without notification to the FDA or the public." HHS Secretary Robert F. Kennedy Jr., March 2025
The Shocking Numbers Behind Food Additives
According to analysis by the Environmental Working Group, since 2000:
Food and chemical companies have used the GRAS loophole to approve 99 percent of new food chemicals
Only one food additive petition for a new chemical has been filed through the formal FDA process
A staggering 756 new food chemicals have been added through the GRAS self-determination process
Even more concerning, experts estimate at least 1,000 substances have been added to the food supply without GRAS notices being submitted to the FDA at all.
How the System Fails Consumers
The current GRAS system suffers from fundamental flaws that undermine food safety:
1. Inherent Conflicts of Interest
Companies can use their own company-funded science to support GRAS determinations and keep this information away from public scrutiny. This creates an obvious conflict where the entities profiting from new ingredients also determine their safety.
2. Complete Lack of Transparency
Under current regulations, both the FDA and the public remain unaware of how many GRAS ingredients are actually in the food supply, particularly those commonly found in ultra-processed foods.
Jennifer Pomeranz, associate professor of public health policy and management at NYU School of Global Public Health, emphasizes this problem: "Both the FDA and the public are unaware of how many of these ingredients—which are most commonly found in ultra-processed foods—are in our food supply."
3. No Meaningful Oversight
Even when companies voluntarily notify the FDA of their GRAS determinations, they can simply withdraw their notifications if the agency raises questions—while still introducing the ingredient into the food supply.
Former FDA Deputy Commissioner for Food, Michael Taylor, acknowledged in 2014 that the FDA "simply does not have the information to vouch for the safety of many of these chemicals."
10 Controversial GRAS Ingredients Currently in Your Food
This regulatory failure isn't just a theoretical concern. Here are real examples of substances with questionable safety profiles that routinely enter our food through the GRAS loophole:
Butylated hydroxyanisole (BHA) - Classified as "reasonably anticipated to be a human carcinogen" by the National Toxicology Program, yet remains GRAS-designated and is found in cereals, potato chips, and chewing gum
Butylated hydroxytoluene (BHT) - May disrupt endocrine function and affect development according to animal studies; commonly used in processed foods alongside BHA
Tara flour - In 2022, consumers experienced liver injury due to this substance that entered the food supply based on a GRAS determination
Carrageenan - A seaweed-derived thickener linked to gastrointestinal inflammation and even cancer in some animal studies; found in many dairy alternatives, ice cream, and processed meats
Synthetic trans fats (partially hydrogenated oils) - Remained GRAS for decades despite clear evidence of cardiovascular harm before finally being phased out by 2018
Brominated vegetable oil (BVO) - Used in citrus sodas and sports drinks, this emulsifier contains bromine (also found in flame retardants) and has been linked to thyroid problems and neurological symptoms
Potassium bromate - Added to flour to strengthen dough, this additive has been linked to cancer in animal studies and is banned in the EU, UK, Canada, China, Brazil, and many other countries, yet remains GRAS in the US
Synthetic flavor enhancers - Ingredients like diacetyl (butter flavor) linked to respiratory issues, and various glutamates that may trigger sensitivity reactions in susceptible individuals
Artificial food colorings - Several, including Red 40 and Yellow 5, have been associated with behavioral issues in children and allergic reactions
Titanium dioxide - A whitening agent used in candies, pastries, and coffee creamers that has been banned in the EU due to potential DNA damage concerns but remains GRAS in the US
The FDA faces significant challenges monitoring ingredients already on the market. The agency rarely revokes GRAS designation—an FDA inventory shows only 15 substances that were once considered GRAS and later determined not to be unsafe.
Recent Policy Shifts That Could Change Everything
On March 10, 2025, newly confirmed HHS Secretary Robert F. Kennedy Jr. directed the FDA to explore eliminating the GRAS loophole entirely. Kennedy stated, "For far too long, ingredient manufacturers and sponsors have exploited a loophole that has allowed new ingredients and chemicals, often with unknown safety data, to be introduced into the U.S. food supply without notification to the FDA or the public."
This federal directive follows state-level actions like the California Food Safety Act, passed in October 2023, which prohibits the statewide sale or manufacture of foods containing four potentially toxic chemical additives allowed through the GRAS process:
Brominated vegetable oil
Potassium bromate
Propylparaben
Red Dye No. 3
At the federal level, legislative proposals include:
Senator Edward Markey's Ensuring Safe and Toxic-Free Foods Act (December 2023), which would require food manufacturers to inform the FDA of new GRAS designations and ban conflicts of interest among experts participating in safety evaluations.
Representative Rosa DeLauro's Toxic Free Food Act (September 2024), which would require all GRAS determinations and supporting evidence to be made publicly available on the FDA website and provide a 90-day period for agency and public review
Industry Pushback: Innovation vs. Safety
Industry stakeholders, particularly those in innovative food sectors like alternative proteins, have expressed concerns that eliminating the self-affirmation process could stifle innovation. The food technology sector argues that increased regulatory hurdles might slow the development of sustainable and healthier food alternatives.
For example, companies developing plant-based meat alternatives often use novel ingredients like leghemoglobin (found in Impossible Burgers) that entered the market through the GRAS process. Similarly, many sustainable protein technologies rely on fermentation processes that produce ingredients not previously used in foods.
The challenge facing regulators is how to strengthen oversight and ensure food safety without unnecessarily impeding food innovation that addresses sustainability concerns, nutritional needs, and evolving consumer preferences.
What This Means For You: Practical Steps
The GRAS loophole highlights a troubling reality: many ingredients in processed foods have never undergone rigorous, independent safety testing. This doesn't mean all such ingredients are unsafe, but it does mean we simply don't know the long-term effects of many substances in our food supply.
For consumers concerned about exposure to potentially harmful additives, consider these approaches:
Focus on whole, minimally processed foods whenever possible — fresh fruits, vegetables, legumes, and minimally processed meats don't contain these questionable additives
Read ingredient labels and avoid products with long lists of chemical additives — a good rule of thumb is to be wary of ingredients you can't pronounce or wouldn't find in a home kitchen
Support brands committed to transparency in their ingredient sourcing and safety — many companies now voluntarily avoid controversial GRAS ingredients
Cook from scratch more often to have complete control over what goes into your food
Follow developments in food safety legislation and consider contacting your representatives about closing the GRAS loophole
Stay informed through reputable sources that track food additives and their safety profiles
The Future of Food Safety Regulation
The coming months will be critical in determining whether this significant gap in America's food safety regulatory framework will finally be addressed. After decades of operating in the shadows, the GRAS system may face its most significant overhaul yet—with profound implications for food safety, public health, and the future of the American food system.
As consumers become more aware of the GRAS loophole and demand greater transparency, the pressure on both regulators and food manufacturers will continue to grow. The question remains: will our food safety system adapt to prioritize public health, or will economic interests continue to dominate the conversation?
Frequently Asked Questions
How can I tell if a product contains ingredients that entered the food supply through the GRAS loophole?
Unfortunately, there's no direct way to identify which ingredients on a label went through the GRAS self-determination process versus formal FDA approval. Your best approach is to focus on whole foods with minimal processing and to research specific additives of concern. Apps like EWG's Food Scores or resources like the Center for Science in the Public Interest's Chemical Cuisine can help you identify potentially problematic ingredients.
Are all GRAS ingredients dangerous? What about things like vitamin C and citric acid that are also GRAS?
Not all GRAS ingredients pose health concerns. Many common food components like citric acid, various vitamins, and plant extracts have established safety records. The concern primarily relates to newer synthetic compounds that entered the market through company self-determinations without independent review. The issue isn't the GRAS designation itself, but rather the lack of transparency and oversight in how some ingredients receive that status.
Is organic food free from GRAS ingredients?
Certified organic foods do prohibit many synthetic additives, but some GRAS substances are permitted in organic products. The USDA National Organic Program maintains a National List of allowed and prohibited substances. Organic processed foods generally contain fewer synthetic additives overall, but may still contain some GRAS ingredients, particularly natural ones like carrageenan. For minimal exposure to questionable additives, focus on whole, unprocessed organic foods rather than processed organic products.