Flavor ingredient regulatory record
3-Hydroxybenzoic acid
3-Hydroxybenzoic acid is an acid in the fruity family, FEMA GRAS under FEMA number 4431 (CAS 99-06-9). Its odor is sweet, tart, berry, floral.
- FEMA
- 4431
- CAS
- 99-06-9
- JECFA
- 2279
- EU FL
- 08.132
- Formula
- C7H6O3
- EC
- 202-726-5
GRAS status: FEMA GRAS, publication 24. Recorded by FDA in the Substances Added to Food inventory under CAS 99-06-9.
Structure
Identity
Also known as: Benzoic acid, 3-hydroxy-, Benzoic acid, m-hydroxy-, m-Hydroxybenzoic acid, m-Salicylic acid, 3-Carboxyphenol, m-Carboxyphenol, NSC 55746, m-hydroxybenzoic acid, m-salicylic acid, 3-carboxyphenol, benzoic acid, 3-hydroxy-, benzoic acid, m-hydroxy-.
Can 3-Hydroxybenzoic acid be labeled natural?
The process decides for 3-Hydroxybenzoic acid. It occurs in nature, so a natural-source, natural-process material is natural flavor in the US and synthetic 3-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.
- 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
3-Hydroxybenzoic acid is FEMA GRAS under FEMA number 4431. 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 08.132, Annex I Part A under Regulation (EC) 1334/2008, evaluation status approved (EFSA). The UK retains the same list.
JECFA (WHO / FAO)
JECFA number 2279, evaluated at the 96th meeting in 2023. 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. 3-Hydroxybenzoic acid appears on the EPA Toxic Substances Control Act Chemical Substance Inventory under CAS 99-06-9, where EPA names it Benzoic acid, 3-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.
Where it is used
3-Hydroxybenzoic acid is used in beverage, confection, fruit flavors, sauces and dressings, typically as a fruity note.
Structurally similar flavor ingredients
Flavor ingredients with a GRAS determination closest to 3-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 |
|---|---|---|---|
| Fumaric acid | 2488 | 79% | In nature |
| L-Malic Acid | 2655 | 78% | In nature |
| Benzoic acid | 2131 | 77% | In nature |
| Succinic acid | 4719 | 75% | In nature |
| L-Aspartic acid | 3656 | 75% | In nature |
More acids in this index
2-Methylbutyric acid · cis- and trans-2-Heptylcyclopropanecarboxylic acid · 4-Pentenoic acid · trans-2-Methyl-2-butenoic acid · 4-Hydroxy-3-methoxy benzoic acid · Levulinic acid
3-Hydroxybenzoic acid FAQ
Is 3-Hydroxybenzoic acid FEMA GRAS?
Yes. The FEMA Expert Panel lists 3-Hydroxybenzoic acid as GRAS under FEMA number 4431. The Code of Federal Regulations lists it at 21 CFR 172.515.
What are the FEMA and CAS numbers for 3-Hydroxybenzoic acid?
3-Hydroxybenzoic acid is FEMA 4431, CAS 99-06-9. Its flavor category is fruity.
How is 3-Hydroxybenzoic acid described, and where does it show up?
Flavorists describe 3-Hydroxybenzoic acid as sweet, tart, berry, floral. It is used in beverage, confection, fruit flavors, sauces and dressings.
What did JECFA conclude about 3-Hydroxybenzoic acid?
JECFA evaluated 3-Hydroxybenzoic acid at the 96th meeting in 2023 under JECFA number 2279. The panel concluded: No safety concern at current levels of intake when used as a flavouring agent.
Is 3-Hydroxybenzoic acid on the EU Union List?
Yes. FL 08.132 is the Union List entry for 3-Hydroxybenzoic acid, annex I Part A, under Regulation 1334/2008, and the UK keeps the same list.
Does 3-Hydroxybenzoic acid count as natural in the US and the EU?
Nature makes 3-Hydroxybenzoic acid, which is why the US label turns on process. A natural route gives natural flavor; synthesis gives artificial 3-Hydroxybenzoic acid, same molecule. In the EU and UK the natural claim likewise needs the natural route, while Mercosur and Mexico keep a third class, identical-to-natural, for the synthetic material.
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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 3-HYDROXYBENZOIC ACID under CAS 99-06-9 and carries its FEMA number. 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.