Flavor ingredient regulatory record
Benzenethiol
Benzenethiol is a thiol in the sulfur family, FEMA GRAS under FEMA number 3616 (CAS 108-98-5). Its odor is pungent, sulfurous, rubbery, earthy.
- FEMA
- 3616
- CAS
- 108-98-5
- JECFA
- 525
- EU FL
- 12.080
- Formula
- C6H6S
GRAS status: FEMA GRAS, publication 12. Recorded by FDA in the Substances Added to Food inventory under CAS 108-98-5.
Structure
Identity
Also known as: Phenol, thio-, Phenyl mercaptan, Thiophenol, Mercaptobenzene, Phenylthiol, NSC 6953, Phenyl hydrosulfide, Phenylmercaptane, thiophenol, mercaptobenzene, phenyl mercaptan, phenylthiol.
Can Benzenethiol be labeled natural?
Benzenethiol occurs in nature, so the label depends on the route: benzenethiol won from a natural source by a physical, enzymatic or microbiological process is natural flavor in the United States, and synthesized benzenethiol is artificial. 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.
- 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
Benzenethiol is FEMA GRAS under FEMA number 3616. 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 12.080, Annex I Part A under Regulation (EC) 1334/2008, evaluation status approved (JECFA). The UK retains the same list.
JECFA (WHO / FAO)
JECFA number 525, evaluated at the 53rd meeting in 1999. No safety concern at current levels of intake when used as a flavouring agent.
Other US flags
Not on the California Proposition 65 list. Listed on the EPA TSCA inventory.
TSCA Inventory status
A flavor ingredient is also an industrial chemical. Benzenethiol appears on the EPA Toxic Substances Control Act Chemical Substance Inventory under CAS 108-98-5, where EPA names it Benzenethiol.
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: Pungent, sulfurous, rubbery, earthy.
Where it is used
Benzenethiol is used in seasoning, sauces, meat products and snack foods, typically as a sulfur note.
Structurally similar flavor ingredients
Flavor ingredients with a GRAS determination closest to Benzenethiol by structure. Whether one can replace it is a sensory and regulatory call; the reformulation tool works that through.
| Material | FEMA | Similarity | Occurrence |
|---|---|---|---|
| Furfuryl mercaptan | 2493 | 89% | In nature |
| 2,6-(Dimethyl)thiophenol | 3666 | 84% | In nature |
| Benzyl mercaptan | 2147 | 79% | In nature |
| Phenol | 3223 | 77% | In nature |
| 1-(2-Thienyl)ethanethiol | 4646 | 77% | Not determined |
More thiols in this index
Phenyl disulfide · Methyl mercaptan · S-Methyl benzothioate · 3-Methylbutanethiol · 2-Mercaptopropionic acid · 2-Mercapto-3-butanol
Benzenethiol FAQ
Does benzenethiol have FEMA GRAS status?
Benzenethiol holds FEMA GRAS status under FEMA number 3616. It is also codified at 21 CFR 172.515.
How do I cite benzenethiol by FEMA or CAS number?
Cite benzenethiol as FEMA 3616 or CAS 108-98-5; both point to the same entry. FEMA files it in the sulfur flavor category.
Can benzenethiol be labeled a natural flavor?
Since benzenethiol is found in nature, US labeling follows how it was obtained: natural flavor from a natural source and a natural process, artificial when benzenethiol is synthesized. 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.
Can benzenethiol be used in the EU and UK?
Benzenethiol is on the EU Union List of flavouring substances as FL 12.080 (Annex I Part A) under Regulation 1334/2008.
Has JECFA evaluated benzenethiol?
Yes. JECFA number 525, evaluated at the 53rd meeting in 1999. Conclusion: No safety concern at current levels of intake when used as a flavouring agent.
What does benzenethiol smell and taste like, and where is it used?
The odor of benzenethiol is pungent, sulfurous, rubbery, earthy. Typical uses are seasoning, sauces, meat products and snack foods.
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Guides: What Is FEMA GRAS? · Natural vs artificial · Filing a GRAS notification
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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 BENZENETHIOL under CAS 108-98-5 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 flavor enhancer, 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.