Food standards in different countries: why the same product varies
The same brand in two countries may have a different composition, and this is not always about cost-cutting. Regulatory systems are structured differently: in some places, a substance is considered permitted until harm is proven, while in others, it is considered prohibited until safety is proven. Almost all the differences a consumer notices stem from this discrepancy.
Two approaches to approval
Positive list. This applies in the EAEU and the EU: only what is included in the list is permitted, with specific products and maximum limits specified. Anything not on the list cannot be used.
Assessment of individual substances as they appear. In a number of jurisdictions, a substance may receive "generally recognized as safe" status based on available data, and the approval process is structured differently.
This leads to a typical situation: an additive is present in an American product but absent in a European one of the same brand—simply because it is not on the list in the second system.
What differs in practice
| What | The difference |
|---|---|
| Additive lists | Different sets of permitted colors and preservatives |
| Warning labels | In the EU, a label regarding the effect of certain colors on children's attention |
| Front-of-pack labeling | Color schemes and point systems are not adopted everywhere |
| Allergen labeling | Lists are similar but not identical |
| Thresholds for claims | "Sugar-free" or "source of protein" are calculated by different rules |
| Units in the table | Sometimes per 100 g, sometimes per serving |
The last row is more problematic in practice than the others: values per serving cannot be compared between products as long as the serving sizes differ. For more on how to read the table itself, see our article on nutritional facts on packaging.
Example: titanium dioxide
A telling case of divergence. In 2021, EFSA concluded that E171 can no longer be considered safe as a food additive, and its use was discontinued in the EU. In other jurisdictions, the decision was different.
This does not mean that one side is right and the other is wrong: different agencies work with different data sets and different rules for handling uncertainty. More details can be found in our article on titanium dioxide.
What is regulated in Russia
Mandatory requirements are set by the technical regulations of the Customs Union: regarding food safety, labeling, food additives, and specific product groups. Labeling rules are governed by regulation TR TS 022/2011.
GOST and TU standards are at a lower level and describe a specific product rather than safety in general. A breakdown is available in our article on GOST and TU.
International level
Above national systems, there is a common layer: the Codex Alimentarius—a collection of international standards from the FAO and WHO—and the Joint FAO/WHO Expert Committee on Food Additives (JECFA), which evaluates additives and establishes acceptable daily intakes. National regulators rely on these assessments but make their own decisions, which is why discrepancies persist.
What this means for the consumer
- Do not apply conclusions across countries. A list of banned substances in one country does not describe the shelves in another.
- Read the ingredients of the specific package. One brand is no guarantee of the same composition.
- Check what the figures refer to. Whether it is per 100 g or per serving determines comparability.
- Check against your own reference guide. The status of each code in Russia and the EU is collected in our E-additive guide.
- Be cautious with "banned in Europe" claims. This phrasing is common but rarely accurate: many substances have a restricted status rather than a total ban.
Frequently asked questions
- Why is an additive permitted in one country and banned in another?
- Because approval systems are organized differently. In the EAEU and the EU, a positive list system is in effect: only substances included in the list can be used. In other jurisdictions, the approval process is different, and the sets of permitted substances vary.
- Can one brand have a different composition in different countries?
- Yes, and this is a common situation. The manufacturer adapts the formulation to the local list of permitted additives, local thresholds for claims, and labeling requirements.
- What regulates the composition of products in Russia?
- Technical regulations of the Customs Union regarding food safety, labeling, and food additives. GOST and TU describe a specific product and are at a lower level.
- Are there common international rules?
- There is the Codex Alimentarius—a collection of international standards from the FAO and WHO—and the Joint FAO/WHO Expert Committee on Food Additives (JECFA), which evaluates additives and determines acceptable daily intakes. National regulators rely on these assessments but make their own decisions.
- Should you trust the phrase "banned in Europe"?
- Verify it. This phrasing is common and rarely accurate: for some substances, the status is restricted by product type and quantity, rather than being completely banned.
Read next
- GOST and TU: what is actually behind these letters — GOST is often read as a mark of quality, while TU is seen as permission to do whatever one wants.
- Titanium dioxide E171: an additive allowed for decades and then banned — Titanium dioxide has been used as a food coloring for decades and was considered one of the most inert additives: it does not dissolve, is not absorbed to any significant degree, and is chemically extremely stable.
- One additive, different rules: why lists do not match — The argument that "this additive is banned in Europe" sounds convincing and almost always requires clarification.
This article is for general information. It is not medical advice, a diagnosis, or a prescription for treatment or a diet, and it does not replace a consultation with your doctor. If you have a health condition, are pregnant, take medication, or follow a diet prescribed to you, decisions about food belong with your doctor.
Figures from regulations, guidelines and studies are given as they stood when this article was prepared and may since have changed; check them against the primary sources. This article is not advertising, an offer, or individual advice, and neither the author nor the site owner is responsible for decisions taken on the basis of it.