DyeConverterTM

Solutions · Ingredient Reformulation

Titanium dioxidereplacement.

Titanium dioxide is still legal in US food, and it is one of the harder ingredients to replace. The options are narrow, so the first question is which ones your product category is allowed to use.

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What the rules say

In the US, titanium dioxide is a listed color additive exempt from certification under 21 CFR 73.575. It is limited to 1 percent by weight of the food, and it cannot be used in standardized foods unless the standard allows added color. It is not a GRAS ingredient.

A petition to revoke that listing was filed on April 14, 2023. It was still marked under review on FDA’s list dated October 28, 2026.

In the EU, E 171 was withdrawn as a food additive by Regulation (EU) 2022/63 after EFSA concluded in 2021 that a concern for genotoxicity could not be ruled out. That is a concern that could not be excluded, not proof of harm, and it applies to EU food rather than US-only products.

We found no US statewide ban on food sales. It is barred from school meals in Arizona and from free and reduced-price school meals in Texas for 2026 to 2027, and it appears on the Texas SB 25 warning list, which is enjoined for the plaintiff associations and their members.

Why whitening is hard to replace

Titanium dioxide whitens and brightens by scattering light. Few other food ingredients do that as efficiently, and suppliers commonly report that replacements need several times the usage rate to approach the same opacity.

The legal list is short, and each entry has limits:

  • Calcium carbonate (21 CFR 73.70): supplement tablets and capsules, soft and hard candies, mints, and inks on chewing gum.
  • Calcium phosphate (21 CFR 73.80): ready-to-eat chicken products, white candy melts, doughnut sugar and sugar for coated candies, each with its own cap.
  • Calcium sulfate: petition filed in September 2026 and not authorized.
  • Rice-based whiteners: sold as alternatives, but confirm the regulatory basis for your use with your supplier and regulatory counsel.

Questions R&D teams ask

Is titanium dioxide legal in US food?

Yes. It is a listed color additive under 21 CFR 73.575, limited to 1 percent by weight of the food and not allowed in standardized foods unless the standard permits added color. A petition to revoke the listing remains under review.

Does the EU ban apply to our US products?

No, it applies to food sold in the EU. If you export there, the product must be free of E 171. EFSA’s conclusion was that a genotoxicity concern could not be ruled out, which is different from a finding of harm.

Do any US states restrict it?

We found no statewide food sales ban. Arizona and Texas restrict it in school food programs for 2026 to 2027, and Texas also lists it under SB 25, whose warning requirement is currently enjoined for the plaintiff associations and their members.

Is titanium dioxide GRAS?

No. It is regulated as a color additive, not as a GRAS ingredient. That matters because anything you use to replace its color function needs its own permitted basis.