Brazil Proposes Major Food Additive Rule Changes 2200 mg/kg Phosphate Limit and New Plant-Based Approvals

On July 8, 2025, Brazil’s ANVISA released Public Consultation No. 1338, seeking feedback on sweeping revisions to food additive and processing aid regulations. The consultation will run from July 15 to August 28, targeting changes to technical functions, maximum levels, and conditions of use (Normative Instruction No. 211/2023).

Key proposals include removing sodium ascorbate and mixed tocopherol concentrates from the approved additives list for certain dairy products and standardizing the maximum limit for most phosphates—such as INS338, 339, 340, 341, and the 450–452 series—at 2200 mg/kg (as phosphorus) in fat emulsions. Tricalcium phosphate used as an anti-caking agent in dietary supplements (INS341) will have a 24-month transition period.

New authorizations are also on the table, including:

• Carrageenan (INS 407) as a stabilizer in imitation dairy drinks, permitted as needed;
• Phosphoric acid (INS 338) up to 950 mg/kg in plant-based beverages like almond milk;
• Sodium polyphosphate (INS 452(i)) as an emulsifier at 9000 mg/kg in processed cheese analogues.

Importantly, activated carbon is newly permitted as a processing aid for plant-based animal product analogues, such as plant-based proteins and milks, with no residue limit required. Stakeholders are encouraged to submit feedback during the consultation period to shape the final rules.