Flavor ingredient regulatory record
BHT
BHT is a phenol in the antioxidant family, FEMA GRAS under FEMA number 2184 (CAS 128-37-0). Its odor is faint phenolic.
- FEMA
- 2184
- CAS
- 128-37-0
- Formula
- C15H24O
- EC
- 204-881-4
GRAS status: FEMA GRAS, publication 3. Recorded by FDA in the Substances Added to Food inventory under CAS 128-37-0.
Structure
Identity
Also known as: Phenol, 2,6-bis(1,1-dimethylethyl)-4-methyl-, p-Cresol, 2,6-di-tert-butyl-, 2,6-Bis(1,1-dimethylethyl)-4-methylphenol, CAO 1, CAO 3, Dalpac, DBPC, Deenax, 2,6-Di-tert-butyl-p-methylphenol, 4-Hydroxy-3,5-di-tert-butyltoluene, Impruvol, Ionol.
Can BHT be labeled natural?
BHT occurs in nature, so the label depends on the route: BHT won from a natural source by a physical, enzymatic or microbiological process is natural flavor in the United States, and synthesized BHT 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
BHT is FEMA GRAS under FEMA number 2184. It is cited in the Code of Federal Regulations at 21 CFR 182.3173.
European Union and United Kingdom
No EU FL number is on file for BHT. That is not a finding either way. The Union List covers defined flavouring substances, so natural complex materials are handled as flavouring preparations under Parts B to F and never receive a number, and substances used as additives sit under Regulation 1333/2008 instead. Confirm the position before EU or UK use.
JECFA (WHO / FAO)
BHT has not been evaluated by JECFA as a flavouring agent, or no evaluation is on file.
Other US flags
Not on the California Proposition 65 list.
TSCA Inventory status
A flavor ingredient is also an industrial chemical. BHT appears on the EPA Toxic Substances Control Act Chemical Substance Inventory under CAS 128-37-0, where EPA names it Phenol, 2,6-bis(1,1-dimethylethyl)-4-methyl-.
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: Faint phenolic.
Taste: Neutral at use levels.
Where it is used
Typical applications for BHT are not on file yet.
Structurally similar flavor ingredients
Flavor ingredients with a GRAS determination closest to BHT by structure. Whether one can replace it is a sensory and regulatory call; the reformulation tool works that through.
| Material | FEMA | Similarity | Occurrence |
|---|---|---|---|
| 4-Acetyl-6-t-butyl-1,1-dimethylindan | 3653 | 69% | In nature |
| alpha-iso-Methylionone | 2714 | 61% | In nature |
| beta-Isomethylionone | 4151 | 60% | In nature |
| 2,4,6-Triisobutyl-5,6-dihydro-4H-1,3,5-dithiazine | 4017 | 55% | Not determined |
| beta-Damascone | 3243 | 53% | In nature |
BHT FAQ
Is BHT FEMA GRAS?
Yes. The FEMA Expert Panel lists BHT as GRAS under FEMA number 2184. It is also codified at 21 CFR 182.3173.
What are the FEMA and CAS numbers for BHT?
BHT is FEMA 2184, CAS 128-37-0. FEMA files it in the antioxidant flavor category.
Does BHT count as natural in the US and the EU?
Since BHT is found in nature, US labeling follows how it was obtained: natural flavor from a natural source and a natural process, artificial when BHT is synthesized. The EU and UK grant the natural claim only to that natural route; Mercosur and Mexico call synthetic material identical-to-natural.
How is BHT described, and where does it show up?
Flavorists describe BHT as faint phenolic. On the palate it is neutral at use levels.
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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 BUTYLATED HYDROXYTOLUENE under CAS 128-37-0 and carries its FEMA number and its 21 CFR citations. The inventory is searchable at FDA. FDA records its technical effect as antioxidant, 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.