Flavor ingredient regulatory record
2-Hydroxybenzoic acid
2-Hydroxybenzoic acid is an acid in the fruity family, FEMA GRAS under FEMA number 3985 (CAS 69-72-7). Its odor is sweet, tart, berry, floral.
- FEMA
- 3985
- CAS
- 69-72-7
- JECFA
- 958
- EU FL
- 08.112
- Formula
- C7H6O3
- EC
- 200-712-3
GRAS status: FEMA GRAS, publication 20. Recorded by FDA in the Substances Added to Food inventory under CAS 69-72-7.
Structure
Identity
Also known as: Benzoic acid, 2-hydroxy-, Salicylic acid, o-Hydroxybenzoic acid, Retarder W, Salicylic acid collodion, Rutranex, Salonil, Psoriacid-S-Stift, Phenol-2-carboxylic acid, 2-Hydroxybenzenecarboxylic acid, 2-Carboxyphenol, o-Carboxyphenol.
Can 2-Hydroxybenzoic acid be labeled natural?
Nature makes 2-Hydroxybenzoic acid, which is why the US label turns on process. A natural route gives natural flavor; synthesis gives artificial 2-Hydroxybenzoic acid, same molecule. The EU and UK grant the natural claim only to that natural route; Mercosur and Mexico call synthetic material identical-to-natural.
- United States
- Natural or artificial, by process
- European Union and UK
- Natural only from natural material
- Mercosur and Mexico
- Natural or identical-to-natural
How each market defines the classes: natural vs artificial flavor under 21 CFR 101.22.
Regulatory status, with citations
United States
2-Hydroxybenzoic acid is FEMA GRAS under FEMA number 3985. It is cited in the Code of Federal Regulations at 21 CFR 172.515.
European Union and United Kingdom
Listed on the Union List of flavouring substances as FL 08.112, Annex I Part A under Regulation (EC) 1334/2008, evaluation status approved (EFSA). The UK retains the same list.
JECFA (WHO / FAO)
JECFA number 958, evaluated at the 57th meeting in 2001. No safety concern at current levels of intake when used as a flavouring agent.
Other US flags
Not on the California Proposition 65 list.
TSCA Inventory status
A flavor ingredient is also an industrial chemical. 2-Hydroxybenzoic acid appears on the EPA Toxic Substances Control Act Chemical Substance Inventory under CAS 69-72-7, where EPA names it Benzoic acid, 2-hydroxy-.
Active in US commerce
EPA designates this substance active, so no Notice of Activity Form B is required before manufacturing. What active and inactive mean.
EPA publishes no regulatory flags on this listing. What the flags mean.
From the EPA non-confidential TSCA Inventory, July 2026 release. EPA also maintains a confidential portion it does not publish. Search the Inventory by CAS number.
Odor and taste
Odor: Sweet, tart, berry, floral.
Taste: Sour, tangy, refreshing.
Where it is used
2-Hydroxybenzoic acid is used in beverage, confection, fruit flavors, bakery and dairy, typically as a fruity note.
Structurally similar flavor ingredients
Flavor ingredients with a GRAS determination closest to 2-Hydroxybenzoic acid by structure. Whether one can replace it is a sensory and regulatory call; the reformulation tool works that through.
| Material | FEMA | Similarity | Occurrence |
|---|---|---|---|
| 2-Hydroxyacetophenone | 3548 | 91% | In nature |
| Benzoic acid | 2131 | 90% | In nature |
| 2-Methoxybenzoic acid | 3943 | 84% | In nature |
| Salicylaldehyde | 3004 | 74% | In nature |
| Methyl salicylate | 2745 | 74% | In nature |
More acids in this index
o-trans-Coumaric acid · 3-Hydroxy-2-oxopropionic acid · 2-Methyl-4-pentenoic acid · Hexanoic acid · 4-Methylnonanoic acid · 3-Hydroxybenzoic acid
2-Hydroxybenzoic acid FAQ
Does 2-Hydroxybenzoic acid have FEMA GRAS status?
2-Hydroxybenzoic acid holds FEMA GRAS status under FEMA number 3985. The Code of Federal Regulations lists it at 21 CFR 172.515.
How do I cite 2-Hydroxybenzoic acid by FEMA or CAS number?
Cite 2-Hydroxybenzoic acid as FEMA 3985 or CAS 69-72-7; both point to the same entry. Its flavor category is fruity.
What does 2-Hydroxybenzoic acid smell and taste like, and where is it used?
The odor of 2-Hydroxybenzoic acid is sweet, tart, berry, floral. On the palate it is sour, tangy, refreshing. Typical uses are beverage, confection, fruit flavors, bakery and dairy.
What did JECFA conclude about 2-Hydroxybenzoic acid?
JECFA evaluated 2-Hydroxybenzoic acid at the 57th meeting in 2001 under JECFA number 958. The panel concluded: No safety concern at current levels of intake when used as a flavouring agent.
Can 2-Hydroxybenzoic acid be used in the EU and UK?
Yes. FL 08.112 is the Union List entry for 2-Hydroxybenzoic acid, annex I Part A, under Regulation 1334/2008, and the UK keeps the same list.
Can 2-Hydroxybenzoic acid be labeled a natural flavor?
The process decides for 2-Hydroxybenzoic acid. It occurs in nature, so a natural-source, natural-process material is natural flavor in the US and synthetic 2-Hydroxybenzoic acid is artificial. The EU and UK grant the natural claim only to that natural route; Mercosur and Mexico call synthetic material identical-to-natural.
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Sources and attribution. The identity and regulatory facts on this page are taken from the FDA Substances Added to Food inventory, a US government record, which lists this substance as SALICYLIC ACID under CAS 69-72-7 and carries its FEMA number, its JECFA flavor number and its 21 CFR citations. The inventory is searchable at FDA. FDA records its technical effect as flavoring agent or adjuvant.
A FEMA GRAS conclusion is reached by the Expert Panel of the Flavor and Extract Manufacturers Association of the United States, and the FEMA number names that conclusion. FEMA publishes its own entry for this substance in the FEMA Flavor Library, which is the authoritative record of what the Panel decided and is worth reading alongside this page.
Ambrose Compliance is not affiliated with, endorsed by, or sponsored by FEMA. FEMA and FEMA GRAS are used here as identifiers for a published regulatory determination, not as marks of any relationship between FEMA and Ambrose.
About this page. Facts come from the FDA Substances Added to Food inventory, the Code of Federal Regulations, the EPA TSCA Inventory, the EU Union List, JECFA and the Ambrose database, with FEMA's published determination cited where it applies; parts of the text are written by Ambrose AI, which can make mistakes. Check the cited source before relying on anything here. This is not regulatory or legal advice.