Flavor ingredient regulatory record
Pyruvic acid
Pyruvic acid is an acid in the acidic family, FEMA GRAS under FEMA number 2970 (CAS 127-17-3). Its odor is sour, pungent, sharp, fruity.
- FEMA
- 2970
- CAS
- 127-17-3
- JECFA
- 936
- EU FL
- 08.019
- Formula
- C3H4O3
- EC
- 204-824-3
GRAS status: FEMA GRAS, publication 3. Recorded by FDA in the Substances Added to Food inventory under CAS 127-17-3.
Structure
Identity
Also known as: Propanoic acid, 2-oxo-, 2-Oxopropanoic acid, Acetylformic acid, BTS, α-Ketopropionic acid, Pyroracemic acid, 2-Oxopropionic acid, NSC 179, MeSH ID: D019289, 2-oxopropanoic acid, acetylformic acid, pyroracemic acid.
Can Pyruvic acid be labeled natural?
Since pyruvic acid is found in nature, US labeling follows how it was obtained: natural flavor from a natural source and a natural process, artificial when pyruvic acid 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.
- 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
Pyruvic acid is FEMA GRAS under FEMA number 2970. 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 08.019, Annex I Part A under Regulation (EC) 1334/2008, evaluation status approved (EFSA). The UK retains the same list.
JECFA (WHO / FAO)
JECFA number 936, 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. Pyruvic acid appears on the EPA Toxic Substances Control Act Chemical Substance Inventory under CAS 127-17-3, where EPA names it Propanoic acid, 2-oxo-.
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: Sour, pungent, sharp, fruity.
Where it is used
Pyruvic acid is used in beverage, sauces, pickling and confection, typically as a acidic note.
Structurally similar flavor ingredients
Flavor ingredients with a GRAS determination closest to Pyruvic acid by structure. Whether one can replace it is a sensory and regulatory call; the reformulation tool works that through.
| Material | FEMA | Similarity | Occurrence |
|---|---|---|---|
| Lactic acid | 2611 | 94% | In nature |
| Glycine | 3287 | 91% | In nature |
| Propionic acid | 2924 | 90% | In nature |
| Hydroxyacetone | 4462 | 86% | In nature |
| Acetoin | 2008 | 82% | In nature |
More acids in this index
Aconitic acid · Tartaric acid (+)-, (-)-, (+/-)-, meso- · Acetic acid · Lactic acid · Propionic acid · Fumaric acid
Pyruvic acid FAQ
Is pyruvic acid FEMA GRAS?
Yes. The FEMA Expert Panel lists pyruvic acid as GRAS under FEMA number 2970. It is also codified at 21 CFR 172.515.
What are the FEMA and CAS numbers for pyruvic acid?
Pyruvic acid is FEMA 2970, CAS 127-17-3. FEMA files it in the acidic flavor category.
Does pyruvic acid count as natural in the US and the EU?
Pyruvic acid occurs in nature, so the label depends on the route: pyruvic acid won from a natural source by a physical, enzymatic or microbiological process is natural flavor in the United States, and synthesized pyruvic acid is artificial. The EU and UK follow the same logic without a middle class; Mercosur and Mexico label synthetic pyruvic acid identical-to-natural.
Is pyruvic acid on the EU Union List?
Pyruvic acid is on the EU Union List of flavouring substances as FL 08.019 (Annex I Part A) under Regulation 1334/2008.
Has JECFA evaluated pyruvic acid?
Yes. JECFA number 936, evaluated at the 57th meeting in 2001. Conclusion: No safety concern at current levels of intake when used as a flavouring agent.
How is pyruvic acid described, and where does it show up?
Flavorists describe pyruvic acid as sour, pungent, sharp, fruity. It is used in beverage, sauces, pickling and confection.
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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 PYRUVIC ACID under CAS 127-17-3 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 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.