No C 354/2 Official Journal of the European Communities 31. 12. 85 
Opinion on the Proposal for a Council Directive amending for the eighth time the Directive 
of 23 October 1962 on the approximation of the rules of the Member States concerning the 
colouring matters authorized for use in foodstuffs intended for human consumption (1). 
(85/C 354/02) 
On 10 October 1985 the Council decided to consult the Economic and Social Committee, under 
Article 100 of the Treaty establishing the European Economic Community, on the above 
mentioned proposal. 
The Section for Protection of the Environment, Public Health and Consumer Affairs, which was 
responsible for preparing the Committee's work on the subject, adopted its opinion on 3 December 
1985, in the light of the report by Mrs Williams. 
At its 232nd plenary session (meeting of 18 December 1985) the Economic and Social Committee 
adopted the following opinion unanimously. 
General observations 
1. The Committee draws attention to the fact that the 
primary purpose of colorants used as additives in the food 
processing industry is to provide sales appeal for foods­
tuffs. 
1.1. Colorants may be synthetic or natural but there is 
no hard and fast rule that natural is 'safer' than synthetic or 
vice-versa. Colorants may also be used in combination with 
other additives such as emulsifiers and stabilizers to ensure 
their effective operation 
1.2. The Committee recognizes that the colouring of 
foodstuffs is widely accepted but is nevertheless aware that 
the whole subject of food additives, including colorants, 
and their possible adverse effects on human health, has 
become a matter of increasing public concern. 
1.3. Accordingly the present proposal, which the 
Committee accepts and considers very timely, should be 
seen not only in the present context of the harmonization of 
foodstuffs legislation but also in the context of possible 
Community action in the fields of public safety, health and 
diet, as well as in the need to avoid misleading the 
consumer. 
2. The Committee recognizes the work which has been 
done in the field of colorants both by the foodstuffs 
industry and by the Scientific Committee for Food, but 
points out that the interpretation of the views of experts can 
diverge or be modified, and emphasizes the need for 
constant review in accordance with the evolution of the 
state of the art. 
2.1. The Committee is also concerned at the inordinate 
length of time it takes at Community level to amend the list 
of authorized colorants, and recommends that this time the 
length be reduced as much as possible. 
3. The Committee also feels that in the past the 
Commission and the Council have had a tendency to be too liberal in permitting the extension of the use of colorants in 
respect of which there have been objections and/or 
divergent views expressed by the Committee, or indeed the 
Scientific Committee for Food. 
4. The Committee draws attention to the continuing 
necessity to inform the public by all appropriate means on 
the interpretation of the EEC numbers and common names 
of the substances used as food colorants. 
4.1. Apart from action in respect of the general public 
there is a need for consumer education and information in 
professional fields — for example an appreciation of the 
real significance of colorants as health hazards (such as 
allergies and hypersensitivities) needs to be built in the 
doctor-patient relationship. 
5. The Committee welcomes all efforts by the Commis­
sion and otherwise to make detailed technical data on 
colorants available to the food processing industry at all 
levels, but notes that the FAO Food and Nutrition criteria 
to which the Commission document refers are not 
published in all Community languages. 
5.1. Steps should be taken to remedy this lack, in order 
that food processors in all Member States should be able to 
implement satisfactorily the provisions of the proposed 
Directive. 
6. The Committee notes with regret that the current 
proposal does not deal with a major defect in Article 1.2. of 
the basic Directive on colorants (2) whereby Member States 
are able to restrict the use of any permitted colouring 
matter providing only that such action does not constitute a 
total prohibition. This provision has allowed divergent 
national legislation to persist and should be reviewed at an 
early date. 
(!) OJ No C 278, 30. 10. 1985, p. 4. (2) OJ No 2645/62, 11.11. 1962. 
31. 12. 85 Official Journal of the European Communities No C 354/3 
7. The Committee welcomes the proposals in the recent 
Commission document on 'completion of the internal 
market: Community legislation on foodstuffs' for the 
official inspection of foodstuffs crossing Community 
frontiers, to ensure that they conform to Community 
criteria, including criteria for colorants. 
8. Finally, the Committee welcomes the introduction of 
the criteria of purity for colorants set out in Annex 2 of the 
Commission's proposal. 
Specific Observations 
Article 1(1) 
The substance 'glycerol triacetate' should also be included 
in this paragraph. 
Article 2 
The time limit of 18 months allowed for the marketing of 
foods containing yellow 2G (which is designed to facilitate 
the sale of long-life products) is too long and should be 
reviewed. 
Annex 1 
E 150 Caramel 
The Committee is pleased to note that its previous 
recommendations (in its opinions on the sixth and seventh 
amendments to the original Directive on colorants) to 
subdivide this item have been followed, and notes that 
whereas it had recommended a subdivision into two kinds 
of caramel, the Commission now proposes a subdivision 
into four. 
However, the committee considers that at least one of the 
common names chosen for those four types — caustic 
sulphite caramel (E 150b) — has a pejorative connotation 
and could be considered misleading under the provisions of 
existing Community legislation on labelling. Accordingly 
the Committee requests the Commission and/or industry to 
re-examine the proposed common names for the subdivi­
sions of caramel to see if more appropriate descriptions 
could be found. 
E 160 d (Lycopene) and 161b to 161f (Xanthophylls) 
The Committee recommends that the proposal to delete 
colorants E 160d (Lycopene) and E 161b to 161f 
(concerning various Xanthophylls) be reviewed. 
Done at Brussels, 18 December 1985. These are natural colorants, which are not used at present 
mainly for economic reasons as they are considerably more 
expensive than synthetic colorants. 
2GE128 Red 
The committee considers that it is not sufficient to define 
'temperature and acidity' as 'high' with reference to this 
substance. More explicit numerical limits should be 
mentioned. 
E 154 Brown FK and E 155 Brown HT 
The committee notes that in respect of these two colorants 
— Brown FK which is used primarily for colouring cured 
fish and Brown HT for general use, e.g. in cakes — in a 
previous opinion it wanted them restricted to the Member 
States (primarily the UK) which used them. 
Annex 2 
The committee proposes that an introductory paragraph be 
added to this annex explaining why continued reference is 
made therein to the FAO Food and Nutrition Paper No 31/ 
1. 
At the same time, the Committee is pleased to note that 
with some minor explicable exceptions, the FAO standards 
to which it is proposed the Community should conform are 
higher than existing standards within the Community. 
E 150 Caramel 
The German text of Annex 2 uses the term 'Lebensmittel-
siifSstoffe' ('food grade nutritive sweeteners') in the 
description of E 150 Caramel. In Germany an official 
definition of 'SuSstoffe' covers a different group of 
substances. It is therefore suggested that the word 
'Suf?mittel' be used instead. 
In conclusion, the Committee notes the urgent nature of the 
present modifications but looks forward to seeing the 
results of the Commission's comprehensive examination of 
its programme on food additives in general, and to the 
laying down of new requirements in food law. 
The Chairman 
of the Economic and Social Committee 
Gerd MUHR