Flavor ingredient regulatory record

Gallic acid

Gallic acid is an acid in the bitter family, FEMA GRAS under FEMA number 4994 (CAS 149-91-7). Its odor is astringent, herbal, woody, slightly sweet.

FEMA
4994
CAS
149-91-7
EU FL
08.080
Formula
C7H6O5
EC
205-749-9

GRAS status: FEMA GRAS. Source: FEMA Flavor Ingredient Library.

Structure

2D structure of Gallic acid
Structure of Gallic acid, C7H6O5. Drawn from the canonical SMILES.

Identity

IUPAC name 3,4,5-trihydroxybenzoic acid
CAS number 149-91-7
FEMA number 4994
Molecular formula C7H6O5
Molecular weight 170.12 g/mol
SMILES O=C(O)c1cc(O)c(O)c(O)c1
InChIKey LNTHITQWFMADLM-UHFFFAOYSA-N
PubChem CID 370
EC number 205-749-9
FDA UNII 632XD903SP
EPA DTXSID DTXSID0020650
Chemical class Acid
Boiling point 501 °C

Also known as: Benzoic acid, 3,4,5-trihydroxy-, 3,4,5-Trihydroxybenzoic acid, NSC 20103, NSC 674319, 3,4,5-Hydroxybenzoic acid, A 1925-04, MeSH ID: D005707, BL 20220429008, 3,4,5-trihydroxybenzoic acid, benzoic acid, 3,4,5-trihydroxy-, gallic acid, tech., pyrogallol-5-carboxylic acid.

Can Gallic acid be labeled natural?

Since gallic acid is found in nature, US labeling follows how it was obtained: natural flavor from a natural source and a natural process, artificial when gallic acid is synthesized. 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

Gallic acid is FEMA GRAS under FEMA number 4994. It is cited in the Code of Federal Regulations at 21 CFR 172.515.

21 CFR 172.515

European Union and United Kingdom

Listed on the Union List of flavouring substances as FL 08.080, Annex I Part A under Regulation (EC) 1334/2008, evaluation status approved (EFSA). The UK retains the same list.

JECFA (WHO / FAO)

Gallic acid 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. Gallic acid appears on the EPA Toxic Substances Control Act Chemical Substance Inventory under CAS 149-91-7, where EPA names it Benzoic acid, 3,4,5-trihydroxy-.

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: Astringent, herbal, woody, slightly sweet.

Taste: Bitter, astringent, tart.

Where it is used

Gallic acid is used in beverage, confection, herbal extracts and food preservatives, typically as a bitter note.

Structurally similar flavor ingredients

Flavor ingredients with a GRAS determination closest to Gallic acid by structure. Whether one can replace it is a sensory and regulatory call; the reformulation tool works that through.

MaterialFEMASimilarityOccurrence
3,4-Dihydroxybenzoic acid443093%In nature
Aconitic acid201079%In nature
4-Hydroxy-3-methoxy benzoic acid398878%In nature
Ascorbic Acid210977%In nature
Propyl Gallate294772%In nature

More acids in this index

cis-4-(2,2,3-Trimethylcyclopentyl)butanoic acid · N-Benzoylanthranilic acid · Aconitic acid · 2-Methyl-2-pentenoic acid · Phenoxyacetic acid · 2-Ethylbutyric acid

Gallic acid FAQ

Is gallic acid on the FEMA GRAS list?

It is. FEMA number 4994 covers gallic acid. It is also codified at 21 CFR 172.515.

What is the FEMA number for gallic acid?

The FEMA number for gallic acid is 4994 and its CAS registry number is 149-91-7. FEMA files it in the bitter flavor category.

Is gallic acid natural or artificial?

Gallic acid occurs in nature, so the label depends on the route: gallic acid won from a natural source by a physical, enzymatic or microbiological process is natural flavor in the United States, and synthesized gallic acid 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.

Is gallic acid approved in the EU?

Gallic acid is on the EU Union List of flavouring substances as FL 08.080 (Annex I Part A) under Regulation 1334/2008.

What is gallic acid used for?

Gallic acid is described as astringent, herbal, woody, slightly sweet. On the palate it is bitter, astringent, tart. It shows up in beverage, confection, herbal extracts and food preservatives.

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Guides: What Is FEMA GRAS? · Natural vs artificial · Filing a GRAS notification

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Sources and attribution. The FEMA number and GRAS status on this page name a conclusion reached by the Expert Panel of the Flavor and Extract Manufacturers Association of the United States. FDA does not list this substance by FEMA number in its Substances Added to Food inventory. Its identity is attested by EU Union List of flavouring substances, EPA TSCA Chemical Substance Inventory, matched on CAS 149-91-7.

FEMA publishes its own entry for this substance in the FEMA Flavor Library, which is the authoritative record 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.