Flavor ingredient regulatory record
Benzyl acetoacetate
Benzyl acetoacetate is an ester in the fruity family, FEMA GRAS under FEMA number 2136 (CAS 5396-89-4). Its odor is sweet, fruity, floral, candy, tropical.
- FEMA
- 2136
- CAS
- 5396-89-4
- JECFA
- 848
- EU FL
- 09.406
- Formula
- C11H12O3
- EC
- 226-416-4
GRAS status: FEMA GRAS, publication 3. Recorded by FDA in the Substances Added to Food inventory under CAS 5396-89-4.
Structure
Identity
Also known as: Butanoic acid, 3-oxo-, phenylmethyl ester, Acetoacetic acid, benzyl ester, Benzyl acetylacetate, Benzyl 3-oxobutanoate, Phenylmethyl 3-oxobutanoate, 3-Oxobutanoic acid phenylmethyl ester, NSC 4391, 3-Oxobutanoic acid benzyl ester, Benzyl 3-oxobutyrate, 3-Oxobutyric acid benzyl ester, benzyl 3-oxobutanoate, acetoacetic acid benzyl ester.
Can Benzyl acetoacetate be labeled natural?
Benzyl acetoacetate occurs in nature, so the label depends on the route: benzyl acetoacetate won from a natural source by a physical, enzymatic or microbiological process is natural flavor in the United States, and synthesized benzyl acetoacetate 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
Benzyl acetoacetate is FEMA GRAS under FEMA number 2136. 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 09.406, Annex I Part A under Regulation (EC) 1334/2008, evaluation status approved (EFSA). The UK retains the same list.
JECFA (WHO / FAO)
JECFA number 848, 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. Benzyl acetoacetate appears on the EPA Toxic Substances Control Act Chemical Substance Inventory under CAS 5396-89-4, where EPA names it Butanoic acid, 3-oxo-, phenylmethyl ester.
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, fruity, floral, candy, tropical.
Where it is used
Benzyl acetoacetate is used in beverage, confection, fruit flavors, bakery and desserts, typically as a fruity note.
Structurally similar flavor ingredients
Flavor ingredients with a GRAS determination closest to Benzyl acetoacetate by structure. Whether one can replace it is a sensory and regulatory call; the reformulation tool works that through.
| Material | FEMA | Similarity | Occurrence |
|---|---|---|---|
| Ethyl 2-acetyl-3-phenylpropionate | 2416 | 76% | In nature |
| Ethyl benzoylacetate | 2423 | 70% | In nature |
| Benzyl salicylate | 2151 | 68% | In nature |
| Propyl phenylacetate | 2955 | 67% | In nature |
| 4-(p-Acetoxyphenyl)-2-butanone | 3652 | 66% | In nature |
More esters in this index
Allyl hexanoate · Isoamyl cinnamate · Propyl hexanoate · cis-Hexenyl tiglate · 2-Acetoxy-3-butanone · 3-Oxododecanoic acid glyceride
Benzyl acetoacetate FAQ
Is benzyl acetoacetate FEMA GRAS?
Yes. The FEMA Expert Panel lists benzyl acetoacetate as GRAS under FEMA number 2136. It is also codified at 21 CFR 172.515.
What are the FEMA and CAS numbers for benzyl acetoacetate?
Benzyl acetoacetate is FEMA 2136, CAS 5396-89-4. FEMA files it in the fruity flavor category.
Does benzyl acetoacetate count as natural in the US and the EU?
Since benzyl acetoacetate is found in nature, US labeling follows how it was obtained: natural flavor from a natural source and a natural process, artificial when benzyl acetoacetate is synthesized. The EU and UK grant the natural claim only to that natural route; Mercosur and Mexico call synthetic material identical-to-natural.
Is benzyl acetoacetate on the EU Union List?
Benzyl acetoacetate is on the EU Union List of flavouring substances as FL 09.406 (Annex I Part A) under Regulation 1334/2008.
Has JECFA evaluated benzyl acetoacetate?
Yes. JECFA number 848, evaluated at the 57th meeting in 2001. Conclusion: No safety concern at current levels of intake when used as a flavouring agent.
How is benzyl acetoacetate described, and where does it show up?
Flavorists describe benzyl acetoacetate as sweet, fruity, floral, candy, tropical. It is used in beverage, confection, fruit flavors, bakery and desserts.
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Guides: What Is FEMA GRAS? · Natural vs artificial · Filing a GRAS notification
Check Benzyl acetoacetate in a formula
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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 BENZYL ACETOACETATE under CAS 5396-89-4 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.