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The Yenzo Scale: how we rate additive risk

Vietnam is the first tier: Circular 24/2019/TT-BYT is the list of permitted additives; Vietnam decides whether an additive is legal, science decides its risk level. An additive not permitted in Vietnam that the scientific evaluations put at the moderate or high level is always at the high level; one missing from the list that they put at the very low or low level keeps that level. Science is the second tier, only where the Vietnamese text is silent: the risk level of each of the 371 additives in the reference (very low, low, moderate or high) rests on the conclusions of JECFA, EFSA and regulators, by the same rule for every additive. The other facts on each page, such as the ADI and the maximum level, come from four legal and scientific sources.

Independent

Yenzo takes no money from food manufacturers or distributors, and no advertising or sponsorship has any bearing on how levels are set. Every additive is rated by the same rule.

The first tier: the status in Vietnam

Vietnam does not evaluate additives itself and sets no ADI; Circular 24/2019/TT-BYT permits an additive or does not, and sets maximum levels by food category. A substance not on the permitted list may not be used (Article 7). Of the 371 additives in the reference, 297 are permitted, 28 are not permitted in Vietnam, 38 are missing from the permitted list but at the very low or low level by the scientific evaluations, and 8 are outside the Circular's scope. Each additive page shows its status:

  • Permitted: the INS number is in Appendix 1 (the page quotes the row), has maximum levels in Appendix 2B, or is in Table 1 or Table 3 of the Codex GSFA, which Appendices 2A and 3 follow (Article 5.5, added by Circular 17/2023/TT-BYT).
  • Not permitted in Vietnam: Codex numbers it as an additive but the permitted list does not have it, and the scientific evaluations put it at the moderate or high level; it may be used only in a product whose declaration is registered with the Vietnam Food Administration. Its risk level is high; the additive's page also shows the level by the scientific evaluations. In the Yenzo app the score of a product with it is at most 39.
  • Not on Vietnam's list of permitted additives: the permitted list does not have it, but the scientific evaluations put it at the very low or low level (for example potassium tartrates E336, fatty acids E570); it may be used only in a product whose declaration is registered with the Vietnam Food Administration. It keeps the level by the scientific evaluations; in the Yenzo app the score of a product with it is at most 59 (“Moderate”).
  • Outside Circular 24/2019: not an additive by its nature, such as a food (gelatine), a vitamin, an enzyme used as a processing aid, or a code missing from the Codex INS list.

The four levels and what each requires

An additive takes the highest level whose conditions it meets. Where a level rests on a contested point, the additive's page names it with its source.

High

This level when any one of these holds: it is not permitted in Vietnam (Circular 24/2019) and the scientific evaluations put it at the moderate or high level; neither JECFA nor EFSA has an ADI for it (never set, withdrawn, or found not suitable as an additive), such as litholrubine BK (E180); a regulator withdrew it for safety reasons and no evaluator kept an ADI afterwards (Red 2G, E128); a direct conclusion about health at the intake from food (nitrites and nitrates, EFSA 2023).

32 of 371

Moderate

This level when any one of these holds: the evaluators disagree, one withdrew or does not permit it for safety reasons while another keeps an ADI (titanium dioxide E171, erythrosine E127, cyclamates E952); a temporary ADI, or one evaluator could not establish an ADI while another has one (the sulphites, carrageenan, hexamethylenetetramine E239); a live safety restriction despite an ADI (the EU's mandatory warning on the six Southampton colours, the EU's limits on aluminium compounds); removed from the EU list with no finding of harm. BHA (E320) is at this level by a recorded decision of its own (IARC Group 2B).

28 of 371

Low

Has an ADI and meets none of the conditions above. The evaluation may be old, new research may have no conclusion yet, or intake may exceed the ADI in some group (phosphates in children, glutamates). Intake above the ADI does not raise the level by itself; the additive's page says so.

142 of 371

Very low

Has an ADI, or needs no numerical ADI, and meets none of the conditions above. Many of these are vitamins, organic acids or substances found in food anyway.

169 of 371

Products for children

  • Food for children under 3 (formula, complementary food): Circular 24/2019 permits only a short list of additives in Codex GSFA food categories 13.1 and 13.2. In such a product an additive outside that list counts at the high level, and the product's score is at most 39; so does a sweetener or colour printed only by its class name, with no code (none is on the list).
  • Products for children from 3: Vietnam has no rule of its own, so the second tier applies. Colours that carry the EU's mandatory warning about activity and attention in children, sweeteners and added caffeine lower the score more than in an ordinary product.
  • Who a product is for is read from the label: an age, “ăn dặm” (complementary food), “trẻ sơ sinh” (infant), a formula stage number, “cho bé” or “trẻ em” (for children).

Four sources for the facts on each page

Vietnam's Ministry of HealthCircular 24/2019/TT-BYT

The list of additives permitted in Vietnam and the maximum level (ML) for each food category.

Consolidated text (PDF)
Codex Alimentarius (FAO/WHO)GSFA, CXG 36

INS numbers, the functional class of each additive and the international list of permitted uses.

GSFA database
EFSAEuropean Food Safety Authority

Re-evaluations of food additives and the acceptable daily intake (ADI).

Food additives at EFSA
JECFA (FAO/WHO)Joint Expert Committee on Food Additives

ADIs and the scientific monographs on each substance.

JECFA database

Risk levels are set by the conditions under “The four levels” below. Today the levels of 101 additives rest on a specific EFSA evaluation, of 21 on a JECFA evaluation or a regulator's decision; the levels of the other 249 rest on the Open Food Facts additive classification, an open project that draws on EFSA's evaluations. Every change is recorded in the changelog.

The order of the sources

  1. Circular 24/2019/TT-BYT: whether the additive may be used in Vietnam and its maximum level in each food category. This is the first tier: an additive that is not permitted and that the scientific evaluations put at the moderate or high level is always at the high level.
  2. JECFA and Codex: Vietnam harmonises with them (Article 4 of Circular 24/2019), so where evaluations differ, JECFA weighs no less than EFSA.
  3. EFSA, the European Food Safety Authority.
  4. The US FDA and other regulators.
  5. Apart from the status in Vietnam, the risk level reflects only the conclusions of these evaluators and restrictions for safety reasons. Being on another country's list, or being allowed in only a few kinds of food, is not a condition for a level.

A risk level is not a “danger” label

A risk level sums up the restrictions and evaluations regulators have placed on an additive. It is not a medical verdict on a product or on your health. The effect depends on dose and context: how much you eat each day, who is eating, and how many products contain it. That is why each additive page also shows the ADI, the status in Vietnam and the sources. If you have a particular health condition, ask your doctor.

How we check

  • Codes, names and risk levels come straight from Yenzo's additive table. When a page is built, its level is compared with the table again; if they differ, the page is not published.
  • Every ADI, every Vietnamese legal status and every answer on a page is checked twice against the original document before publication: once while writing, and again in a separate checking step. Anything the source does not confirm is not published.
  • We do not use words such as “harmful”, “toxic” or “dangerous” without a source. They appear only in a reader's own question, or in a regulator's conclusion quoted word for word with a link.
  • An additive missing from the permitted list is described as the Circular has it: “not permitted in Vietnam”. We do not call it “banned”: the Circular lists only what is permitted.

Updates and corrections

When a source document changes, such as a new circular or a new EFSA or JECFA opinion, we update the affected pages and record it in the changelog.

Spotted a mistake? Tap “Report inaccurate information” at the bottom of any page or write to support@yenzo.app. We look at every report within 7 days.

ChangelogWhen each correction was made, what changed and which pages it touched

Updated: 29 October 2026

Information only, not medical advice. The risk level is the additive's class in Yenzo's open scoring method, based on the cited source.

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