The same INS code on a food label can be treated very differently from one country to the next. A colour the European Union has pulled from food can still be permitted in India, and a warning the EU prints on a pack may not be required here at all. This is a look at a few specific, source-verified cases where EU and Indian food-additive rules diverge, drawn from our hand-curated dataset of common Indian-label additives. It is informational, not medical or dietary advice.
Quick Facts
| Case | European Union | India (FSSAI) |
|---|---|---|
| Titanium dioxide (INS 171) | Food-additive authorisation withdrawn from 2022 | Permitted as a colour at GMP levels for specified categories |
| Warning-label dyes (INS 102, 110, 122, 124, 129) | Permitted; covered foods carry a child-attention warning, subject to Annex V exceptions | Permitted for specified categories and limits, with no equivalent warning required |
| Veg dot vs animal-origin additives | No vegetarian / non-vegetarian mark system | Beeswax and shellac (animal and insect origin) are excluded from the non-veg mark; carnauba is plant-derived |
How we checked
We did not audit every additive in our dataset. For this piece we selected specific cases and verified each one against primary regulation: the EU food-additive rules and EFSA opinions on the European side, and the FSS (Food Products Standards and Food Additives) Regulations 2011 plus the FSS (Labelling and Display) Regulations 2020 on the Indian side, with the JECFA evaluations where relevant. Each additive named below links to its own entry, and the primary sources are listed at the end.
Titanium dioxide (INS 171): withdrawn in the EU, permitted in India
Titanium dioxide is the bright white colour in some candy shells, chewing gum, and frosting. The official positions on it differ:
- European Union. After the European Food Safety Authority concluded in 2021 that it could no longer be considered safe as a food additive, the EU withdrew its authorisation as a food additive under Regulation (EU) 2022/63, in force from 7 February 2022 with a transition period to 7 August 2022. Its use in medicines was separately reviewed and maintained by the European Commission in 2025.
- India. FSSAI permits titanium dioxide as a colour at Good Manufacturing Practice levels for specified food categories.
- JECFA and the United States. The Joint FAO/WHO Expert Committee on Food Additives, a scientific advisory body rather than a regulator, reaffirmed the ADI "not specified" in 2023, concluding no concern at currently estimated dietary exposures. In the United States, titanium dioxide remains permitted as a colour, limited to 1 percent by weight of the food (21 CFR 73.575).
The divergence is real but specific: the EU acted on a genotoxicity concern at the nanoparticle scale that other assessments weighed differently. The full entry, with sources, is at titanium dioxide (INS 171).
The warning-label dyes
Six synthetic colours, known as the Southampton Six after the 2007 study that prompted the rule, must carry the statement "may have an adverse effect on activity and attention in children" on covered foods in the EU, subject to the exceptions set out in Annex V. Five of those six are permitted in India for specified categories and limits, with no equivalent warning required on the label:
| Colour | INS | In India |
|---|---|---|
| Tartrazine | 102 | Permitted for specified uses; no warning required |
| Sunset Yellow FCF | 110 | Permitted for specified uses; no warning required |
| Azorubine (Carmoisine) | 122 | Permitted for specified uses; no warning required |
| Ponceau 4R | 124 | Permitted for specified uses; no warning required |
| Allura Red AC | 129 | Permitted for specified uses; no warning required |
The sixth, quinoline yellow (E104), is not on India's permitted list. The point here is the label gap: within its permitted uses, the same dye that triggers a printed caution in the EU can appear in an Indian product with only the usual colour declaration.
An India-specific point: what the green veg dot does not catch
This last one is not an EU-versus-India difference but a gap inside India's own labelling rule, and it matters for vegetarian and Jain shoppers. Under the FSS (Labelling and Display) Regulations 2020, FSSAI requires the brown non-vegetarian mark for additives of animal origin, but the rule expressly excludes a few: milk, honey, beeswax (INS 901), carnauba wax (INS 903), and shellac (INS 904). Of these, beeswax and shellac are the animal and insect-derived ones (carnauba wax is plant-derived, from a palm). So a product whose only animal-origin ingredient is beeswax or shellac can still carry the green vegetarian dot.
🧪What a shopper can actually do
None of this needs alarm. The practical move is to read the INS codes on the back of the pack rather than the marketing on the front. If you want to avoid a specific additive, note its number and check the ingredient list. If you eat strict vegetarian, Jain, or vegan, the green dot is a useful signal but not a complete one, so beeswax and shellac are worth knowing by name.
🧪Bottom line
Food-additive rules are not global. Titanium dioxide is out of EU food but permitted in India, five of the EU's warning-label dyes are permitted here without that warning, and India's veg dot leaves out beeswax and shellac. Knowing the INS codes lets you read the pack for yourself. This is informational and not a substitute for professional dietary or medical advice.
Sources
- Titanium dioxide. EFSA 2021 re-evaluation of E171 (EFSA Journal 2021;19(5):6585); the EU withdrawal of food-additive authorisation, Regulation (EU) 2022/63; the European Commission 2025 review maintaining medicinal use, SWD(2025) 244; the United States 1 percent limit, 21 CFR 73.575; and India's permission under Appendix A of the FSS (Food Products Standards and Food Additives) Regulations 2011 (FSSAI compendium).
- Warning-label dyes. The EU child-attention warning and its exceptions are set in Annex V of Regulation (EC) 1333/2008 (for E102, E104, E110, E122, E124, E129). India's permitted synthetic colours are set in Appendix A of the FSS (Food Products Standards and Food Additives) Regulations 2011.
- Veg dot. The non-vegetarian mark and its exclusions (milk, honey, beeswax, carnauba wax, shellac) are set in the FSS (Labelling and Display) Regulations 2020, notified 14 December 2020.