The Lacuna Project

lacuna (n.) a gap in a record where something should be

Independent research. Not affiliated with any government, agency, or company.

Exhibit 564

Navigating the U.S. Food Additive Regulatory Program (Comprehensive Reviews in Food Science and Food Safety 10(6):342-368)

Exhibit 564 ยท Peer-reviewed study

Navigating the U.S. Food Additive Regulatory Program (Comprehensive Reviews in Food Science and Food Safety 10(6):342-368)

assigning the more than 10000 substances currently allowed in human food to those categories

Source of the estimate, based on interviews with food-industry staff and review of public GRAS notices and reports, that as of January 2011 more than 10,000 additives were in use, including about 1,000 human-food substances whose makers had concluded GRAS status without telling FDA. FDA's 2026 economic analysis adopts it as the low end of its own range. The estimate excludes flavors in the FEMA library and substances in common use before 1958.

Source
Neltner TG, Kulkarni NR, Alger HM, Maffini MV, Bongard ED, Fortin ND, Olson ED (Pew Health Group)
Date
25 October 2011
Quoted from
Abstract, Compr. Rev. Food Sci. Food Saf. 10(6), Nov. 2011 (Wayback snapshot of the journal page, 2023-01-09)
Grade
Peer-reviewed
Document
https://ift.onlinelibrary.wiley.com/doi/full/10.1111/j.1541-4337.2011.00166.x
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Not opened. Known through the JAMA paper (which restates the estimate), FDA's 2026 proposed rule (refs. 6-7) and FDA's 2026 PRIA (ref. 4, footnote 2).

Cited by

Finding AGR-1.7
Primary record FDA's 2026 economic analysis states that the exact number of substances marketed under independent GRAS conclusions is unknown and assumes 1,000 to 3,000 (primary estimate 2,000), against 1,309 notices filed from February 1998 to March 2025. The proposed rule states that FDA "cannot verify the accuracy of these estimates."