Yellow No. 5 (Tartrazine) and Yellow No. 6 (Sunset Yellow) Ban: Regulatory-Compliant Replacement Strategies

Table of Content

FD&C Yellow No. 5 (Tartrazine, E102) and FD&C Yellow No. 6 (Sunset Yellow FCF, E110) are synthetic azo dyes historically used in food and beverage systems for their high tinctorial strength, heat stability, and cost efficiency. However, increasing regulatory scrutiny, pediatric behavioral safety concerns, and clean-label pressures have accelerated restrictions, mandatory warning labels, and de facto bans across multiple global markets. For multinational food and beverage manufacturers, these regulatory divergences have converted Yellow 5 and Yellow 6 from formulation conveniences into compliance liabilities.

This document provides a structured, R&D-focused technical assessment of regulatory-compliant color alternatives, supplier-validated options, formulation implications, and implementation pathways for replacing Yellow 5 and Yellow 6 in food and beverage matrices while maintaining chromatic performance, processing stability, and shelf-life integrity

Why Replace Yellow No. 5 & Yellow No. 6

Yellow 5 and Yellow 6 belong to the azo dye class, metabolically reducible to aromatic amines under certain gastrointestinal conditions. EFSA re-evaluations and post-market surveillance studies have linked these dyes to hyperactivity concerns in children, triggering mandatory labeling under EU Regulation (EC) No 1333/2008 and the “Southampton Six” warning framework. While still permitted in the U.S. under FDA CFR Title 21 with certification requirements, their acceptance is eroding due to retailer bans, school food restrictions, and export incompatibility.

From an R&D risk perspective, continued reliance on Yellow 5 and 6 introduces formulation lock-in to region-specific SKUs, increases reformulation cost over time, and complicates global harmonization strategies. Replacement is therefore driven not only by regulatory compliance but also by portfolio resilience, consumer perception risk mitigation, and long-term innovation alignment.

Regulatory Landscape

RegionYellow No. 5 (Tartrazine)Yellow No. 6 (Sunset Yellow)Regulatory Notes
EURestricted (E102)Restricted (E110)Mandatory hyperactivity warning
UKRestrictedRestrictedPost-Brexit alignment retained
US (FDA)PermittedPermittedCertification & labeling required
CanadaPermittedPermittedUsage monitored
India (FSSAI)RestrictedRestrictedLimited food categories
Australia/NZRestrictedRestrictedClean-label driven phase-outs
Retailer StandardsDe facto bannedDe facto bannedMajor global retailers

Suppliers of Natural Yellow Colorants for Yellow No. 5 & 6 Replacement

1. GNT Group (Netherlands / Global)

    Derived from edible fruits, vegetables, and plants using physical processing without chemical solvents, EXBERRY® yellow shades rely on carotenoid-rich matrices (pumpkin, safflower, carrot). Typical color strength ranges from 1-3% dosage depending on application opacity. pH stability is optimal between 3.0-7.0, with moderate thermal stability up to 90-110 °C for short-time processes.

    Water-dispersible systems dominate beverage and confectionery use. Regulatory approvals include EFSA, FDA (coloring foods), FSSAI, and Codex compliance. Certified Non-GMO, Kosher, Halal, and suitable for vegan labeling across beverages, bakery, confectionery, and dairy alternatives.

    2. Sensient Food Colors (USA / Global)

    Sensient offers both oil- and water-soluble yellow systems using annatto (bixin/norbixin) and curcumin standardized to >95% purity. pH stability varies by carrier system, with curcumin performing optimally below pH 7 and annatto suitable for neutral dairy matrices. Thermal stability extends to UHT under controlled oxygen exposure.

    Typical dosage ranges from 5-150 ppm active pigment. Regulatory clearances include FDA 21 CFR, EFSA E100/E160b, and global market approvals. ISO 9001, FSSC 22000, Kosher, and Halal certifications support multinational deployment.

    3. Chr. Hansen (Denmark / Global)

    These systems use carotenoid-rich raw materials processed via enzymatic and mechanical extraction, delivering clean-label “fruit and vegetable concentrate” declarations. Stability is matrix-dependent, with optimal performance in acidic beverages and gummies. Light stability is enhanced through encapsulation.

    Dosage typically ranges from 0.1-0.5% depending on opacity. Approved under EFSA coloring food guidance, FDA coloring food policy, and Codex standards. Widely applied in beverages, confectionery, and fermented dairy analogs.

    4. DDW, The Color House (USA)

    DDW specializes in annatto-derived norbixin for aqueous systems and bixin for fat-based applications. pH stability spans 4.5-8.0 depending on formulation. Heat stability supports HTST and baking applications. Dosage ranges from 10-50 ppm active pigment.

    Regulatory compliance includes FDA, EFSA, and FSSAI. Certified ISO, Kosher, Halal, and Non-GMO. Commonly used in cheese, sauces, snacks, and beverage emulsions.

    5. Kalsec (USA / Global)

    Kalsec utilizes solvent-free extraction and antioxidant-stabilized systems to improve oxidative resistance. Curcuminoid purity typically exceeds 90%, with optimized emulsions for beverage clarity. pH performance is strongest below neutral, with thermal tolerance up to pasteurization conditions.

    Regulatory approvals cover FDA, EFSA, and clean-label retailer standards. Applications include beverages, savory snacks, and plant-based foods.

    Need Yellow No. 5 & Yellow No. 6 free suppliers relevant to your product? Fill out the form to access a product-mapped supplier list.

    Segmentation of Alternatives by Scientific Domain

    Carotenoid Chemistry Systems

    Carotenoid-based yellows (curcumin, beta-carotene, annatto) rely on conjugated double-bond chromophores that provide vibrant hues but exhibit sensitivity to light and oxygen. Encapsulation and antioxidant pairing are critical to mitigate oxidative degradation during shelf life.

    Coloring Food Concentrates

    Whole-food concentrates function via native pigment matrices embedded within polysaccharide and protein carriers. These systems offer superior label acceptance but lower tinctorial efficiency and higher batch variability.

    Emulsion-Stabilized Pigment Systems

    Oil-dispersed carotenoids stabilized with emulsifiers improve clarity and color uniformity in beverages. Droplet size distribution directly influences hue saturation and cloud stability.

    Hybrid Botanical Blends

    Multi-pigment blends combining turmeric, safflower, and carrot allow spectral tuning to match Yellow 5/6 shades. However, interactions between pigments complicate stability modeling.

    Research Gaps & White-Space Opportunities

    1. Photostability Modeling Deficiencies
      Current predictive models inadequately capture carotenoid photodegradation kinetics under retail lighting, limiting shelf-life forecasting accuracy.
    2. High-Temperature Processing Limits
      Natural yellow systems show inconsistent chromatic retention during extrusion and retort processing, requiring improved heat-resistant encapsulation strategies.
    3. Matrix-Dependent Hue Drift
      Interactions between natural pigments and proteins, minerals, or acids remain poorly quantified, leading to unpredictable shade variation across formulations.
    4. Multi-Phase Beverage Compatibility
      Emulsion-based yellows exhibit instability in low-pH, low-Brix beverages with high ionic strength, indicating a need for novel stabilizer systems.
    5. Cost-Performance Optimization
      Achieving parity with synthetic dyes in cost-in-use remains unresolved, especially for high-volume beverage applications.

    Comparative Technical Table

    Active CompoundMechanism of ColorStability ProfileRegulatory StatusPerformance vs Yellow 5/6
    CurcuminPolyphenolic chromophoreLight-sensitiveGlobal approvalModerate
    Annatto (Norbixin)Carotenoid saltHeat-stableGlobal approvalHigh
    Beta-CaroteneConjugated carotenoidOxygen-sensitiveGlobal approvalModerate-High
    Coloring FoodsNative pigment matrixProcess-dependentLabel-friendlyModerate

    Formulation Considerations

    Replacement of Yellow 5 and 6 requires careful management of solubility systems, antioxidant protection, and packaging barriers. Oxygen transmission rate (OTR) and light exposure become critical shelf-life determinants.

    Dosage recalibration is required due to lower tinctorial strength, impacting cost-in-use and potential flavor interactions. Label declarations shift from additive codes to ingredient-based descriptions, influencing regulatory classification and marketing claims.

    R&D Implementation Framework

    1. Audit & Risk Mapping – Identify SKU exposure across regions and processing conditions.
    2. Screening of Alternatives – Bench-test pigment systems under matrix-specific stress conditions.
    3. Trial Design – Conduct accelerated stability, light, and heat trials.
    4. Data Integration – Align sensory, regulatory, and shelf-life data.
    5. Scale-Up – Validate supply continuity, batch consistency, and cost modeling.

    Conclusion

    The regulatory trajectory for Yellow No. 5 and Yellow No. 6 clearly favors phased elimination in food and beverage systems. While natural yellow alternatives introduce formulation complexity, advancements in carotenoid chemistry, emulsion technology, and coloring food systems enable technically viable, globally compliant replacements when approached through structured R&D frameworks.

    Want to know how to replace Yellow No. 5 and Yellow No. 6 while maintaining global regulatory compliance and formulation performance? Fill out the form to receive a customized regulatory and formulation insight.

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