Flavor ingredient regulatory record
Phosphoric Acid
Phosphoric Acid is a flavoring substance, FEMA GRAS under FEMA number 2900 (CAS 7664-38-2).
- FEMA
- 2900
- CAS
- 7664-38-2
- Formula
- H3O4P
- EC
- 231-633-2
GRAS status: FEMA GRAS, publication 3. Recorded by FDA in the Substances Added to Food inventory under CAS 7664-38-2.
Structure
Identity
Also known as: Orthophosphoric acid, EVITs, WC-Reiniger, Sonac, Decon 4512, Kefo, 3M Etching Liquid, C 134 (acid), C 434 (acid), C 134, C 434, Mikro Klene DF.
Can Phosphoric Acid be labeled natural?
Phosphoric Acid occurs in nature, so the label depends on the route: Phosphoric Acid won from a natural source by a physical, enzymatic or microbiological process is natural flavor in the United States, and synthesized Phosphoric Acid is artificial. The EU and UK follow the same logic without a middle class; Mercosur and Mexico label synthetic Phosphoric Acid 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
Phosphoric Acid is FEMA GRAS under FEMA number 2900. It is cited in the Code of Federal Regulations at 21 CFR 182.1073.
European Union and United Kingdom
No EU FL number is on file for Phosphoric Acid. 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)
Phosphoric 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. Listed on the EPA TSCA inventory.
TSCA Inventory status
A flavor ingredient is also an industrial chemical. Phosphoric Acid appears on the EPA Toxic Substances Control Act Chemical Substance Inventory under CAS 7664-38-2, where EPA names it Phosphoric acid.
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
Taste: Acid taste.
Where it is used
Typical applications for Phosphoric Acid are not on file yet.
Structurally similar flavor ingredients
Flavor ingredients with a GRAS determination closest to Phosphoric Acid by structure. Whether one can replace it is a sensory and regulatory call; the reformulation tool works that through.
| Material | FEMA | Similarity | Occurrence |
|---|---|---|---|
| N-Lactoyl ethanolamine phosphate | 4257 | 56% | Not determined |
| Acetic acid | 2006 | 51% | In nature |
| Sulfur Dioxide | 3039 | 44% | In nature |
| Formic acid | 2487 | 42% | In nature |
| Alanine | 3252 | 36% | In nature |
Phosphoric Acid FAQ
Is Phosphoric Acid on the FEMA GRAS list?
It is. FEMA number 2900 covers Phosphoric Acid. It is also codified at 21 CFR 182.1073.
What is the FEMA number for Phosphoric Acid?
The FEMA number for Phosphoric Acid is 2900 and its CAS registry number is 7664-38-2.
Is Phosphoric Acid natural or artificial?
Since Phosphoric Acid is found in nature, US labeling follows how it was obtained: natural flavor from a natural source and a natural process, artificial when Phosphoric Acid is synthesized. The EU and UK follow the same logic without a middle class; Mercosur and Mexico label synthetic Phosphoric Acid identical-to-natural.
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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 PHOSPHORIC ACID under CAS 7664-38-2 and carries its FEMA number and its 21 CFR citations. The inventory is searchable at FDA. FDA records its technical effect as antimicrobial agent, flavor enhancer, flavoring agent or adjuvant, fumigant, malting or fermenting aid, non-nutritive sweetener, ph control agent, sequestrant.
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.