GRAS (Generally Recognized as Safe) Notification

Food manufacturers are always on the lookout for ways to improve their products. While ingredients like sugar, chocolate, and vanilla have been around for centuries, there are other ingredients that aren’t quite so old but are still valuable to modern food makers. In this article, we’ll cover everything you need to know about FDA GRAS certification: what it is, how it works, and why you should consider getting your ingredients certified by the FDA as GRAS substances.

FDA Response to GRAS Notification

The FDA responds to GRAS Notifications within 180 days from the date of original filing. However, the Authority also reserves the right to extend the review timeline by 90 days. So the total number of days can be 270.

US FDA GRAS Database

GRAS Notification Overview

“GRAS” is an acronym for ‘Generally Recognized As Safe.’ Any substance to be added to a food product in the US must obtain a GRAS status before it (the substance) is added to the product. GRAS status is given to the proposed use of an ingredient. In general, two separate ways can be adopted to obtain GRAS recognition.

  1. A GRAS Notification – With GRAS Notification to the FDA, the government issues a letter after an assessment is conducted.
  2. Self GRAS Determination – With this method, the FDA is not involved. The stakeholder is solely liable for verifying safe use with the review of an expert panel.

A self-determination GRAS dossier follows all of the same steps as a GRAS notification and format with the exception that the dossier is not submitted to the FDA. The majority of GRAS dossiers are self-affirmed.  We can help you prepare a self-affirmed GRAS dossier.

What is GRAS?

ingredients that they have determined to be safe for human consumption. As you might imagine, this process is voluntary—but it’s also required in order for companies to sell certain products in the United States.

GRAS notification is different than GRAS status. A company can send the FDA evidence that their product is GRAS through a voluntary notification process (or VNP), but only if they have received approval from their local regulatory agency first. For example, the FDA has not yet determined whether CBD oil is safe enough to consume as a food ingredient, so there are no VNPs on file at this time.

FDA GRAS Guidance
GRAS Substances

What are the different categories of GRAS substances?

The FDA recognizes three categories of GRAS substances: those that the FDA has declared generally safe, those that have scientific consensus from expert panels, and those ingredients determined to be GRAS by independent sponsors who evaluate a substance’s safety and then submit evidence to the FDA for review. All three categories must meet the same criteria for safety. It is important to understand the different types of GRAS in order to properly list them on your product label.

What are some examples of GRAS substances?

Many substances are considered GRAS, including common food ingredients like salt, sugar, and vinegar. Other examples of GRAS substances include:
– Ascorbic acid (vitamin C)
– Citric acid
– Calcium chloride
– Glycerin
– Sodium bicarbonate (baking soda)

It’s worth noting that just because a substance is considered GRAS doesn’t mean it’s without risk. However, the risk associated with GRAS substances is generally regarded as low.

GRAS
GRAS Status

Why is GRAS important for food safety?

Understanding GRAS is essential for ensuring compliance with FDA regulations and avoiding potential legal issues if you work in the food industry. If a substance is not considered GRAS and is used in a food product, it may be subject to pre-market approval by the FDA, which can be lengthy and expensive.  

This certification is an important step for companies looking to expand their product lines or reach a wider audience. The FDA GRAS certification process can be daunting, but when completed successfully can open new doors for your business. Our team has worked with clients across the globe on their GRAS submissions and we have helped them achieve success. If you are interested in learning more about our services or want help getting started on your own submission, please contact us today!

They must pass FDA safety reviews and are approved for food use that meets specific requirements. GRAS is important to understand because it can affect the labels on your food product. Labeling should list all substances with GRAS status, such as “GRAS Flavors” or the individual ingredient names on their label. Understanding how these ingredients impact your labeling is essential for compliance with FDA rules and regulations.

How is a substance designated GRAS?

Determining whether a substance is GRAS is a complex and rigorous process that thoroughly evaluates all available scientific data. At a high level, the method for determining whether a substance is GRAS involves two main steps:
1. Experts in the field evaluate the substance’s safety: A panel of experts in toxicology, chemistry, and other relevant fields assesses the security of the substance based on all available scientific data. This includes data from animal and human studies and data on the substance’s chemical structure, potential toxicity, and other factors.
2. The FDA reviews the data and makes a determination: After the expert panel has evaluated the substance’s safety, the FDA reviews the data and decides whether the substance is GRAS. If the FDA determines that the substance is not GRAS, it may require pre-market approval before it can be used in food products.

What are the GRAS labeling requirements?

If a substance is considered GRAS, it does not need to be listed on a food label. However, if a substance is not considered GRAS and is used in a food product, it must be listed on the label. This GRAS labeling process ensures that consumers are aware of all ingredients in the food they consume.

food safety certifications, GRAS Ingredients, EFSA, HACCP, SFCR
European Food Safety Authority (EFSA) Novel Food Pathway

Which foods contain GRAS preservatives?

As a rule, most foods that contain preservatives have been granted GRAS status by the FDA. For example, baked goods like bread and cakes are generally safe for consumption because of ingredients such as sodium benzoate, which is used to keep mold from growing on foods. Canned foods such as sauces may also contain sodium benzoate or potassium sorbate to prevent spoilage. Chocolate and cocoa products like chocolate milk often contain the artificial sweetener aspartame or sucralose for preservation purposes, while other dairy products like cheese slices are preserved through lactic acid cultures such as Lactobacillus rhamnosus GG (LGG).

However, not all foods containing GRAS preservatives are widely available at supermarkets due to limited demand in certain areas of the United States or other countries around the world; instead, they’re usually only available at specialty stores or online retailers located within those particular regions where they’re sold most commonly today

How to comply with food labeling requirements when using GRAS Ingredients?

The FDA requires that all GRAS (generally recognized as safe) ingredients must be clearly identified on the finished product’s labels. This ensures that manufacturers can accurately report which ingredients have been used in the product and, more importantly, it enables customers to make knowledgeable decisions about their dietary choices. Additionally, GRAS ingredients must also be accompanied by an affirmative statement of safety as established through scientific procedures. When labeling products containing GRAS ingredients such as preservatives and flavorings, businesses should include a declaration indicating the identity of each ingredient listed and its function in the food product.

Food Labeling Requirements GRAS Ingredients
GRAS Preservatives

What is the difference between GRAS and food additives?

It’s important to note that not all food additives are considered GRAS. Many food additives require pre-market approval by the FDA before being used in food products. The main difference between GRAS substances and food additives is that GRAS substances are generally recognized as safe based on a long history of use in food. In contrast, food additives may be new or have a limited account of food use.

Our skilled team can help you navigate through the complex GRAS Notification process by assisting with the entire paperwork submission. We will:

  • Determine whether GRAS status is required for your ingredient
  • Help with a successful regulatory strategy
  • Detect scientific and technical data gaps and suggest solutions
  • Conduct research for scientific evidence to ensure substance is safe 
  • Prepare and submit GRAS notifications and liaison with the FDA
  • Mediate expert panel reports on GRAS conclusions
  • Self-affirmed GRAS compliance
  • Choosing between ODI, NDI, GRAS food certification
GRAS Notification

Frequently Asked Questions

FDA responds to GRAS Notifications within 180 days from the date of original filing. However, the Authority also reserves the right to extend the review timeline by 90 days. So, the total number of days is 270.

“GRAS” is an acronym for ‘Generally Recognized as Safe.’ Any substance to be added to a food product in US must obtain a GRAS status before it (the substance) is added to the product.

A GRAS Notification provides a voluntary mechanism whereby a person may inform the FDA of a determination that the use of a substance/ingredient is generally recognized as safe.

A self-determination GRAS dossier follows all the same steps as a GRAS notification and format with the exception that the dossier is not submitted to the FDA. Most GRAS dossiers are self-affirmed.  We can help you prepare a self-affirmed GRAS dossier.  

Self GRAS Determination – In this method, FDA is not involved. The stakeholder is solely liable for verifying safe use with the review of an expert panel.

Our expert team is skilled to help you navigate through the complex GRAS Notification process by assisting with the entire paperwork submission. Our services include:

  • Determine whether GRAS status is required for your ingredient
  • Help with a successful regulatory strategy
  • Detect scientific and technical data gaps and suggest solutions
  • Research for scientific evidence to ensure substance is safe 
  • Prepare and submit GRAS notifications and liaison with FDA

Mediate expert panel reports on GRAS conclusions

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