A Tale of Two Food Standards: How the UK and US Differ in Protecting Consumers
In a world where we increasingly question what goes into our food, a striking divide exists between how the United Kingdom and the United States regulate food additives. The differences aren’t subtle—they represent fundamentally contrasting philosophies about consumer safety and corporate responsibility. The UK adopts a precautionary approach, requiring manufacturers to prove additives are safe before they enter the food supply. Meanwhile, the US system often allows substances until evidence mounts that they’re harmful. This divergence creates a curious situation where items on American grocery shelves contain ingredients already banned across the Atlantic, raising questions about what exactly we’re consuming with our daily meals.
The philosophical gap between these regulatory frameworks reflects broader societal values. British food regulations embody the “better safe than sorry” principle, proactively removing suspicious substances from the food chain. Their system prioritizes preventative measures, banning additives that show even potential for harm in research studies. This precautionary stance contrasts sharply with America’s more industry-friendly approach, which places a higher burden on proving harm than proving safety. The result is a transatlantic food divide where British shoppers enjoy certain protections that Americans don’t yet have. This reality has increasingly caught the attention of health advocates and policymakers in the US, including Health and Human Services Secretary Robert F. Kennedy Jr., who has announced plans to phase out eight petroleum-based food dyes—though many other concerning ingredients remain in circulation.
Consider potassium bromate, a synthetic powder widely used in American commercial baking. This white crystalline substance strengthens gluten networks in flour, creating fluffier, higher-rising, and whiter bread products—qualities American consumers have come to expect. It’s a baker’s helper that improves texture and appearance, but at what cost? The UK banned this substance back in 1990 after research showed it caused cancer in laboratory animals. Despite these findings, potassium bromate remains legal in the United States within certain concentration limits, though the FDA has it under review. California has taken matters into its own hands, becoming the first state to ban the ingredient, though the prohibition won’t take effect until 2027. This timeline demonstrates how slowly the American regulatory system sometimes responds to potential health concerns, allowing years of continued exposure even after problems have been identified.
Perhaps even more concerning is azodicarbonamide—colloquially known as the “yoga mat chemical” due to its dual use in both food production and industrial applications like manufacturing yoga mats and shoe soles. This versatile synthetic compound improves bread texture and whitens flour while also helping produce foam plastics. The nickname itself raises immediate questions: should we be eating something also used to make exercise equipment and footwear? Health researchers and organizations have warned that repeated inhalation of this substance, particularly in workplace settings, may cause asthma. More troublingly, its chemical byproducts have generated cancer concerns. Despite these red flags, the FDA continues to permit azodicarbonamide with certain restrictions, though it has announced a review of its approval. The UK, meanwhile, has already determined this substance doesn’t belong in food at all and has prohibited its use.
The summer of 2023 brought another illustration of this regulatory divide when Jolly Rancher candies came under scrutiny in the UK. The popular sweets were found to contain mineral oil aromatic hydrocarbons (MOAH) and mineral oil saturated hydrocarbons (MOSH)—chemical compounds primarily derived from crude oil. These substances typically enter food through contaminated packaging or during production processes. The UK’s Food Standards Agency didn’t mince words in its June alert, stating: “MOAH can cause damage to DNA and has the potential to increase the risk of cancer, particularly if consumed in high quantities over a prolonged period of time.” While MOSH exposure isn’t generally considered as concerning, research into long-term effects continues. The stark contrast in regulatory response is telling: the UK immediately flagged these products as containing illegal substances, while the US hasn’t even established specific regulatory limits for these compounds in food.
As consumers become more health-conscious and information about food ingredients more accessible, the pressure on American regulators to adopt stricter standards grows. Secretary Kennedy’s commitment to “Make America Healthy Again” by “examining and addressing the root causes of the chronic disease epidemic” suggests potential regulatory shifts ahead, though an HHS spokesperson declined to “comment on future or potential policy decisions.” The gap between UK and US food standards reminds us that what we eat isn’t just a matter of personal choice but also of public policy. The ingredients in our food reflect political decisions, corporate influence, and societal values around risk and safety. As Americans become more aware that their food contains substances deemed too risky for British consumers, they may increasingly question why their protection standards differ and demand the same precautionary approach that keeps potentially harmful additives off UK plates. Until then, the transatlantic food divide remains, with American consumers often unknowingly consuming ingredients their British counterparts have been protected from for decades.