With today’s focus on “clean” labels, food manufacturers are replacing artificial colors with colors from “natural” sources. Some of these substances have perceived health benefits or may act as food preservatives, increasing the potential for consumer over exposure. A substance that has been determined safe for one purpose, at one level of use, is not necessarily safe for additional uses either because of increased acute exposure or frequent/repeated exposures that may have cumulative effects. Further, just because a substance is from a natural source does not mean that it is safe for all levels of consumption. Some of the most toxic substances known to humans occur in foods naturally, and ingestion must be limited to avoid toxicity.
Recognizing that certain food additives may be subject to overuse, the European Union has established a mandatory monitoring and reporting program for use and intake of food additives in Member States. No such system currently exists in the United States. Using a German database on the occurrence of additives, Diouf and coworkers recently performed an assessment of consumption of food colors in toddlers and children, two vulnerable populations due to high energy intake relative to body weight. The study included two food colors from natural sources – cochineal (E120), which colors food red, and annatto (E160b), which colors food orange-red. Intakes of cochineal in toddlers and children were lower than the ADIs for both mean and 95th percentile consumers, so the results for cochineal are not discussed here. The study showed that use of annatto is generally confined to a few foods (e.g. cheese, desserts, and breakfast cereals) that are commonly consumed by children, putting children at risk of over exposure. Mean intakes of annatto in children aged 6 months to 5 years (young children) slightly exceeded the acceptable daily intake (ADI), and 95th percentile intakes for young or older children were approximately double the ADIs. Thus, at the current level of usage in Germany, infants, toddlers and children are at risk of overconsumption of annatto. As the dietary habits of children and accessibility of foods containing annatto in the United States are not expected to differ substantially from Germany, it is altogether possible that some children in the United States may currently be consuming too much annatto. Consumption of annatto extract by children is expected to increase, as major food manufacturers are using the extract to replace synthetic red colors in foods commonly eaten by children, such as cereal and macaroni and cheese.,
Another substance that may be in danger of overuse in food is turmeric (including its oleoresin), which contains curcumin and other curcuminoids. In the United States, turmeric is approved for use as a color additive and a flavor. Because turmeric has purported health benefits, food manufacturers may be tempted to increase use levels for permitted uses, in order to make claims. Restrictions have not been placed on use of turmeric as a color or flavor, other than “amounts consistent with good manufacturing practice”, which is generally understood to mean the minimum amount necessary to achieve the technical effect. Because the FDA has not established mandatory reporting of use of food additives, it is difficult for the FDA to track use of turmeric and enforce the “amount consistent with good manufacturing practice” clause. Therefore, there is high potential for overuse of turmeric. Curcuminoids from turmeric are also permitted for use as a flavor in certain foods at concentrations providing intake of up to 3 mg/kg bw/day curcumin, (the ADI). Because consumers of foods containing the ingredient curcuminoids from turmeric may already consume curcumin at the ADI, they should limit curcumin consumption from other sources, including turmeric and curry. People who tend to develop kidney stones should also limit consumption of turmeric, as ingestion of dietary supplements containing high amounts of turmeric has been shown to increase urinary oxalate levels.
Because turmeric is increasingly being used as a color additive in foods children tend to eat, such as macaroni and cheese and cereal,4,5 children are particularly at risk of consuming too much turmeric or curcumin. The mean and the 95th percentile intake estimates of curcumin for 1- to 10-year old children are above the ADI of 3 mg/kg bw/day in some European countries.8 In the United States, sources of curcumin, rather than curcumin itself, are authorized for use in food; therefore the European estimates for curcumin intake may not apply to the United States. To estimate current curcumin consumption by children in the United States, we inputted publicly available usage rates for approved curcumin-containing flavor ingredients (turmeric, turmeric extract, turmeric oleoresin and curcuminoids from turmeric) into our proprietary consumption program, adjusting for curcumin content of turmeric, turmeric extract and turmeric oleoresin (4%, 15% and 55%, respectively)..,, We also reported EFSA’s estimate of curcumin intake in children from the use of turmeric and curry as a spice,8 as it is expected that consumption of turmeric and curry as a spice would not differ significantly between European and American children. The analysis does not include use of turmeric as a color additive, as specific usage rates are not defined by regulation, and could be highly variable. For the purpose of this exercise, the body weight of a child was estimated to be 20 kg, the 50th percentile weight of a six year old male, according to the CDC. The results show that average consumption of curcumin by children in the United States is 2.9 – 3.9 mg/kg bw/day (Table 1), slightly higher than the ADI of 3.0 mg/kg bw/day. The 90th percentile level of curcumin intake by children (the value used by FDA to determine safety of food ingredients) is approximately two to three times the ADI. Values of curcumin consumption obtained from our consumption analysis are similar to those reported by EFSA for 1-10 year old European children of 3.4 mg/kg bw/day at the mean and 7.1 mg/kg bw/day at the 95th percentile.8 As recipes for macaroni and cheese utilize higher amounts of turmeric than are typically used as a flavor, it is obvious that use of turmeric as a color in foods that will be consumed by children may lead to levels of curcumin consumption significantly higher than the ADI, if consumption of curcumin from other foods is not limited.
Interestingly, the need for replacement of synthetic colors in food was predicated by an association between consumption of these substances with hyperactivity in children. The “natural” replacements for these colors may produce more serious effects in children than the original colors, if their use is so widespread that it leads to unsafe levels of consumption. As use of colors from natural sources increases, the hazard potential will increase. Manufacturers should resist the temptation of using the same color in a wide variety of foods, and consumers should take care to read labels and purchase foods with different coloring agents to avoid over consumption of colors that are in favor.
To help determine whether use of your color could cause toxicity due to overconsumption, contact Burdock Group.
 Dolan LC, Matulka RA and Burdock GA. Naturally occurring food toxins. Toxins 2010; 2:2289-2332.
 European Parliament and the Council of the European Union. Regulation (EC) No 1333/2008, Chapter V, Article 27, 2008.
 Diouf F, Berg K, Ptok S, Lindtner O, Heinemeyer G, Heseker H. German database on the occurrence of food additives; application for intake estimation of five food colours for toddlers and children. Food Additives & Contaminants. Part A. 2014;31(2): 197-206.
 General Mills. General Mills cereals removing artificial flavors and colors from artificial sources. http://www.generalmills.com/en/News/NewsReleases/Library/2015/June/artificial-cereals/4044ee9e-dc51-482d-bca7-58165fc18042. Published June 22, 2015. Accessed January 2, 2016.
 Kraft Foods Group. Iconic Kraft Macaroni & Cheese to remove synthetic colors and artificial preservatives in the U.S. in 2016. http://newscenter.kraftfoodsgroup.com/phoenix.zhtml?c=253200&p=irol-newsArticle&ID=2037718. Published April 20, 2015. Accessed January 8, 2016.
 FDA. GRAS Notice No. 460, for curcuminoids purified from turmeric. http://www.accessdata.fda.gov/scripts/fdcc/?set=GRASNotices&id=460&sort=GRN_No&order=DESC&startrow=1&type=basic&search=460. Published February 28, 2013. Accessed January 6, 2016.
 Sabinsa Corporation. Determination of the Generally Recognized as Safe (GRAS) Status of Curcumin (Curcumin C3 Complex) as a Food Ingredient. http://www.fda.gov/downloads/Food/IngredientsPackagingLabeling/GRAS/NoticeInventory/ucm346902.pdf. Published February 28, 2013. Accessed January 11, 2016.
 EFSA. Scientific opinion on the re-evaluation of curcumin (E100) as a food additive. EFSA Journal. 2010; 8(9):1679.
 Tang M, Larson-Meyer DE, Liebman M. Effect of cinnamon and turmeric on urinary oxalate excretion, plasma lipids, and plasma glucose in healthy subjects. Am. J. Clin. Nut. 2008;887:1262-7.
 Burdock GA. Fenaroli’s Handbook of Flavor Ingredients, Sixth Edition. Boca Raton, FL: CRC Press; 2010: 1964-1966.
 The program utilizes food intake data from the 2011-2012 What We Eat in America Survey
 Chattopadhyay I, Biswas K, Bandyopadhyay U and Banerjee RK. Turmeric and curcumin: Biological actions and medicinal applications. Curr. Sci. 2004; 87: 44-53.
 Pothitirat W. and Gritsanapan W. Variability of curcuminoids: Antioxidative components in ethanolic turmeric extract determined by UV and HPLC methods. Acta Hortic. 2008;786:175-184.
 Henry BS. Natural food colors. In: Hendry GAF and Houghton JD, eds. Natural Food Colorants, Second Edition. Glasgow, NZ: Blackie Academie & Professional;1996:70.
 21 CFR §73.600 states that turmeric may be used as a food color in amounts consistent with good manufacturing practice.
 The estimates include consumption of curry and turmeric as spices and assume that children consuming foods containing turmeric, turmeric extract and turmeric oleoresin do not consume foods containing curcuminoids from turmeric.
 Available recipes at http://ohsheglows.com/2009/05/10/healthy-comfort-food-vegan-mac-and-cheese/ and
http://www.angiesbigloveoffood.com/2011/06/secret-ingredient-mac-cheese.html, accessed February 10, 2016, mention use of 1/8 tsp for 4 ounces of pasta, or ½ tsp for 1 pound of pasta, which convert to 2.5 g turmeric/480 g pasta, or 5208 parts per million.