Understanding Food Additive E-Number Labelling in the European Union

E-numbers are not “extra chemicals” — they are simply the EU’s standardized identification system for authorised food additives. The compliance risk usually comes from how an additive is declared: functional class, naming, special statements (especially for sweeteners), and consistent documentation across labels, specs and export files.

This article explains the practical rules manufacturers and exporters should follow to reduce non-compliance, relabelling costs and border delays. It is written for technical, regulatory, QA and procurement teams working with additives such as sweeteners, preservatives, acidulants, hydrocolloids, emulsifiers and phosphates.

1) Foundations

What E-numbers mean in the EU

Why the EU uses E-numbers, how they relate to functional classes, and how additives are authorised.

2) Practical labelling

Ingredient list declaration rules

Functional class + (name or E-number), compound ingredients, carry-over, and typical pitfalls.

3) High-risk topics

Sweeteners & special statements

“With sweeteners”, aspartame phenylalanine statements, and tips for consistent export labels.

Definition

E-number = authorised additive

If an additive is permitted in the EU, it is assigned an E-number (e.g., citric acid = E 330). The E-number improves consistency across languages and simplifies regulatory lists and labels.

Not a “grade”

E-number is not quality grade

E-numbers do not indicate purity, particle size, or performance grade. Those are managed through specifications (e.g., food grade compliance, assay, microbiology, mesh size, etc.).

Functional classes

Additives have functions

EU labelling is function-based: “preservative”, “antioxidant”, “thickener”, “emulsifier”, “acid”, “colour”, “sweetener”, etc. The function determines what must appear before the additive name/E-number in the ingredients list.

Typical E-number ranges (quick orientation):

E 100–199: Colours
E 200–299: Preservatives
E 300–399: Antioxidants & acidity regulators (broadly)
E 400–499: Thickeners, stabilisers, emulsifiers (many hydrocolloids fall here)
E 500–599: Acidity regulators, anti-caking agents, raising agents (many salts)
E 900–999: Sweeteners, glazing agents, gases, foaming agents (varies)

Safety assessment

Risk assessment and scientific review

An additive must pass safety evaluation and be used at levels that are safe for consumers. Authorisation is tied to defined food categories and maximum permitted levels or quantum satis conditions.

Technological need

Function must be justified

Additives are permitted when there is a technological need (e.g., preservation, texture, stability) and use does not mislead consumers.

Conditions of use

Permitted list + restrictions

“Authorised” does not mean “allowed everywhere.” Your compliance check must confirm the additive is permitted in your exact food category and at your intended use level.

Practical takeaway: labelling compliance depends on both (a) correct declaration and (b) correct use within permitted categories/limits. Your label may be perfectly written — and still be non-compliant if the additive is used outside permitted conditions for that product type.

Operational recommendation

Keep a “regulatory decision file” per product

For each finished product (or each base formulation), keep a short internal file containing: permitted category justification, usage level rationale, spec sheets, CoA template, allergen statement (if relevant), and the final approved ingredient declaration (all languages). This is the fastest way to answer customer questionnaires and audits.

Core rule

Use: functional class + specific name OR functional class + E-number

In the EU, additives in the ingredient list are generally declared by stating their functional class followed by either: (a) the specific name, or (b) the E-number. The functional class is not optional when the ingredient is functioning as an additive.

Examples (typical style):

Preservative: calcium propionate or preservative: E 282
Acidity regulator: citric acid or acidity regulator: E 330
Thickener: xanthan gum or thickener: E 415
Emulsifier: lecithins or emulsifier: E 322
Antioxidant: ascorbic acid or antioxidant: E 300

One ingredient, multiple roles

Pick the relevant function

Some substances can act in multiple roles (e.g., citric acid can be an acidulant, acidity regulator, chelator). Your declared function should match what it is doing in the product.

Naming consistency

Choose a naming strategy and apply it

Decide whether your brand labels declare by E-number or by name, then keep it consistent across markets and languages. Inconsistent naming often triggers customer technical questions and relabelling requests.

Do not over-claim

Avoid “additive-free” traps

If a functional additive is present, it must be declared. Using “processing aid” language to avoid declaration is high-risk unless the ingredient truly qualifies as a processing aid under your regulatory interpretation and local enforcement practice.

Common pitfalls

Top 7 mistakes that cause EU label non-compliance

Missing functional class (e.g., writing “E 415” without “thickener”).
Wrong functional class (e.g., calling a stabiliser a “thickener” when its main role is suspension stability).
Declaring trade names instead of specific additive names (e.g., “Stabilizer Blend 12”).
Compound ingredient confusion (premixes/blends not broken down correctly).
Ignoring sweetener statements (“with sweeteners” near the name of the food).
Aspartame/phenylalanine statement missing (when applicable).
Mismatch between label and spec/CoA (customers compare these during approval).

Sweeteners statement

When sweeteners are used

Foods containing one or more added sweeteners commonly require the statement “with sweetener(s)” near the name of the food. If both added sugars and sweeteners are present, the statement is typically “with sugar(s) and sweetener(s)”.

Aspartame warning

Phenylalanine statement

Where aspartame or aspartame-acesulfame salt is used, EU labelling rules require a phenylalanine-related statement. In practice, you will see either “contains aspartame (a source of phenylalanine)” or “contains a source of phenylalanine” depending on how the sweetener is designated in the ingredients list.

Operational tip

Lock sweetener statements early

Sweetener declarations can change with small recipe changes (e.g., adding a small amount of sugar for flavour balance). Freeze the “name-of-food statement” during label approval to prevent rework.

Practical examples

How it looks on finished product labelling (examples)

Zero-sugar soda: “Cola drink with sweeteners” + ingredient list includes “sweeteners: …”
Reduced sugar lemonade (sugar + sweetener): “Lemonade with sugars and sweeteners”
Product with aspartame: ingredients list + required phenylalanine statement where applicable

Note: Always align the final wording with your local regulatory advisor and the destination member state enforcement practice, especially for multilingual labels and private-label templates.

Premixes

Vitamin/mineral premixes

Premixes often contain carriers (e.g., maltodextrin) and flow agents. Ensure your internal documentation shows a full breakdown and that the label reflects ingredient requirements for your product type.

Stabiliser blends

Hydrocolloid/emulsifier systems

If you buy a stabiliser blend, you still need to declare the relevant additives correctly. Avoid listing only a trade name. Ask suppliers for a disclosure list suitable for label creation.

Bakery improvers

Enzymes + emulsifiers + acids

Bakery improver systems can include enzymes, emulsifiers and acids. Carefully distinguish additives vs. ingredients, and manage “processing aid” interpretations conservatively to reduce risk.

Supplier request template

What to request from your additive supplier for EU labelling

Product name + additive identity (including E-number where applicable)
Functional class / technological function in typical applications
Full qualitative composition for blends/premixes (including carriers and processing aids)
Specification sheet (assay, limits, microbiology as applicable)
CoA template + typical analysis values
Allergen statement and contamination controls (where relevant)
GMO statement, irradiation statement, Halal/Kosher certificates if needed
Shelf life and storage conditions; packaging details

Checklist

Before you approve the label

Identity: Do you know the exact additive identity and E-number (if used on label)?
Function: Is the functional class correct for how the additive is used in this product?
Declaration format: Functional class + (name or E-number) applied consistently?
Sweeteners: Is “with sweeteners” (or “with sugars and sweeteners”) required and included near the food name?
Aspartame: If aspartame/aspartame-acesulfame salt is present, is the phenylalanine statement correctly included?
Compound ingredients: Are premixes/blends handled correctly (no trade-name-only declarations)?
Permitted use: Is the additive permitted in this product category and at the intended level?
Document alignment: Label matches specification sheets, CoA language, customer questionnaires and export docs?
Translation control: Are multilingual versions technically equivalent (same functions and additive identities)?

Short disclaimer

Important note

This article provides general technical guidance and common industry practice. It is not legal advice. EU requirements can vary in interpretation and enforcement across member states and product types. For high-stakes launches, confirm final wording and category permissions with a qualified regulatory professional.

Specifications