Request To Revoke Color Additive Listing for Use of Titanium Dioxide in Food
The Pet Food Institute (PFI) appreciates the opportunity to provide comments regarding the agency’s May 3, 2023, request for public input concerning a color additive petition (filed with the agency on April 14, 2023) proposing to repeal the color additive regulation providing for the use of titanium dioxide in foods (21 CFR 73.575).
Established in 1958, PFI is the trade association and the voice of U.S. cat and dog food manufacturers. Our members account for the vast majority of the pet food and treats made in the United States, with more than $50 billion in domestic annual dog and cat food and treats sales and annual exports of more than $2.4 billion. PFI membership also includes companies that supply ingredients, equipment, and services to dog and cat food makers. We are all proud to be feeding over 186 million dogs and cats in U.S. households.
PFI supports the continued use of titanium dioxide as a safe and approved color additive. Color additives such as titanium dioxide (21 CFR 73.575) intended for use in animal foods, including pet food and treats, are approved by FDA (in this case the Center for Food Safety and Applied Nutrition) following the same intended use requirements as foods for human consumption. These are listed under 21 CFR 73 and 74 and establish the common or usual name for these color additives.
Titanium dioxide has been used as an approved and effective color additive in pet food products and treats since FDA evaluated and approved its use in the 1960’s. This additive brings with it a distinctive white color that is significant in providing greater appeal to pet owners as they provide safe and proper nutrition to their pets. During the more than fifty-year history of safe use of titanium dioxide in pet food, PFI members are unaware of any credible complaints or reports of illness caused to pets associated with titanium dioxide.
PFI has reviewed the European Food Safety Authority (EFSA) opinion on titanium dioxide (published in May 2021) – cited in the food additive petition as the basis for the requested repeal — and found that, although thorough, most factors documented in the paper were not able to conclude toxic effects on either humans or animals attributable to the color additive’s use. PFI’s own interpretation of this paper is that it does not support the requested repeal of 21 CFR 73.575 Titanium Dioxide as a color additive. Importantly, the EFSA justification for banning titanium dioxide as a color additive in the European Union was based on direct inhalation of particles rather than ingestion of a finished food. Due to the manufacturing and process controls used in the making of pet food formulas, the inhalation of titanium dioxide simply would not occur and would be considered negligible in a hazard evaluation as required by the Food Safety Modernization Act.
On behalf of PFI members, whose nearly 30,000 employees in 33 states provide safe food for the 186 million pets across the United States, we appreciate the opportunity to share our views and look forward to an outcome from this petition that will continue to allow for the safe use of titanium dioxide in food for dogs and cats.
President and CEO Pet Food Institute
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Kelly Kanaras, Director of Communications