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Color

Color is a regulated ingredient

Updated

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Color in food is an additive with a listing, not a cosmetic choice.

The structure

Color additives are listed by regulation: part 73 holds those exempt from certification, part 74 those subject to certification, and part 82 the provisional listings. A color is permitted for a particular use because a regulation lists it for that use.

Certification is a batch process

The colors in part 74 are subject to certification under section 721(c) of the Act, which is why 101.22(k)(1) points at that part when it requires them to be named. A certified color carries a batch identity behind it.

Listed for a use, not listed in general

A color cleared for one food category is not thereby cleared for every one, and some listings carry limits. So the question to ask a supplier is which regulation lists this for the use you intend.

Which makes "food grade" an unhelpful phrase

It is not a defined term in the regulation and it is used loosely in trade. The defined position is a listing in part 73, 74 or 82 for the use, and that is what a specification should state.

Four of the nine leaves here are colorants

Food coloring, cake decor, sprinkles and edible glitter. So for most of this group the color is not an incidental additive, it is the product, which is an unusual position among the properties in this library.

And the declaration follows from the listing

Whether you may write "Artificial Color" or must write "Blue 1 Lake" depends on which part the color sits in. The listing decides both legality and labeling, so it is one question rather than two.

Get the listing reference in writing

Not a marketing sheet. The regulation and the use it covers, from the supplier, kept with the formula. It is the single most useful document in this category.

References

21 CFR parts 73, 74 and 82, the listings of color additives exempt from certification, subject to certification, and provisionally listed. A color additive is lawful for a use because it is listed for that use, which is the authority 101.22(k) points at. law.cornell.edu
21 CFR 101.22(k), on declaring coloring in the statement of ingredients. Paragraph (k)(1) requires a color additive subject to certification to be declared by the name listed in part 74 or part 82, with "Lake" included where it is a lake; (k)(2) allows "Artificial Color", "Artificial Color Added" or "Color Added" only for colors not subject to certification and not otherwise required to be named. law.cornell.edu
Written from federal statute and regulation, not from a kitchen. Food labeling has more parts than three sections, and a state cottage food program may add or subtract requirements for a local sale. Nothing here is clearance for a specific label, and whether an ingredient is cleared for food use is a question about that ingredient.