Food Additives and the Need to Show a Technical Effect in Food

As the scientific community refines its focus on the “functionality” of food and as industry looks for ways to capitalize on that focus, there is a commensurate need for precision in discussing and describing the contours of applicable legal authority for assessing functionality. This short article examines one aspect of that authority: the Food and Drug Administration’s ability to demand a showing of functionality for a food additive. The limitations and possibilities we find may be surprising.…