NATCOL Position Papers

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A NATCOL position paper is a document, or collection of documents, that presents an opinion about an issue. Position papers range from the simplest format of a letter to the editor through to the most complex in the form of an academic position paper. The NATCOL position papers are made public to document the problem and what we believe to be a solution. Topics will be varied but focused entirely on Food Colours or Food Colouring only.

In May and June 2015 the European Food Safety Authority (EFSA) published opinions on the safety of the chlorophyll colours. Chlorophyll E 140(i) is a normal part of the diet so is considered safe.

However, because the critical toxicological studies date back to the 1950s, EFSA concluded that more current research or safety data is required before it could assess the safety of:

  • Chlorophyllins E 140(ii),
  • Copper complex of Chlorophylls E 141(i) or
  • Copper complexes of Chlorophyllins E 141(ii) (Copper Chlorophyllins).

For this reason the EFSA ANS Panel was unable to establish a firm opinion relating to these colours.

EFSA Scientific Opinion on re-evaluation of chlorophyllins (E 140(ii)) as food additives
EFSA Scientific Opinion on re-evaluation of copper complexes of chlorophylls (E 141(i)) and chlorophyllins (E 141(ii)) as food additives

NATCOL met with the European Commission at the end of September 2015 to express its commitment to collaborate with the authorities to address the data gaps and at the same time formally asked that these colours are retained on the market during that process.

NATCOL therefore registered as interested party to the call for data published by DG SANTE in May 2017 for providing scientific and technical data on the permitted food additives E 140(i) chlorophylls, E 140(ii) chlorophyllins, E 141(i) copper complexes of chlorophylls and E 141(ii) copper complexes of chlorophyllins

Since, it confirmed its commitment through submitting a project plan to the European Commission to provide the needed data for E 140(i) chlorophylls. The other chlorophyll products will be taken care of by a NATCOL member company, FMC (who’s health and nutrition business became part of DuPont on November 1st), which also provided a task plan for E 140(ii), E141(i) and E141(ii).

NATCOL will continue to work to ascertain that the expected scientific and technical data will be provided to support the future use of all of these chlorophyll products.

NATCOL position on Chlorophyll Colour


NATCOL Position Paper on Colouring Foods

NATCOL Position Paper on Colouring Foods

EU Guidance Notes Colouring Food 2013


Selective Extraction Criteria


NATCOL Decision Tree


Executive Summary

The food colour market faces a changing pattern of demand with more value growth in natural’ food colours at the expense of ‘artificial’ colours. Food manufacturers are replacing ‘artifical’ colours by more ‘natural’ colours and even scrutinizing the differences among the ‘natural’ colours. Terms such as ‘without artificial colour’ are prominently displayed on food packaging. But what are those marketing claims about? How do they translate into which colours were added to the finished foods making such claims? In order to provide clarity, NATCOL furnishes this position and guidance document which is a consensus reflection of the views of NATCOL member companies. NATCOL classifies food colours into four categories based on the key discriminators:

  • occurrence in nature,
  • source material used, and
  • manufacturing process employed.

Per category, NATCOL proposes ‘natural’ related voluntary labelling options such as “natural”, “natural origin” or “non-artificial”. The full classification of the colours and the labelling options are presented in annex I and II.

The technical classification (decision tree) that leads to the four colour categories and the related labelling scheme are provided in annex II. All information in this document, in particular summarised information as in annex I and II, must be considered in the context of the whole document and in particular the legal notice in section 5.


Purpose of the present NATCOL document is to classify food colours between the two poles of ‘natural’ and ‘artificial’ by their varying degrees of perceived naturalness. The document is intended to serve as the basis and technical justification for the NATCOL food colours categorisation scheme in annex I and II. It reflects current thinking of NATCOL members on the naturalness of food colours in relation to voluntary label claims used on finished food labels. An attempt is made to propose marketing claims for food colours which under appropriate circumstances may be used in a way that is truthful and not misleading to consumers. The document has a clear focus to the European market and legal framework. Due to the lack of legal definitions the document might serve as important guidance of interpretation as it reflects the common opinion of the food colour industry represented in NATCOL.

NATCOL Position on the Term “Natural Colour” and the categorisation of Food Colours


Annex 1 : Categorisation of Food Colours


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