국가별 식품첨가물 인산염류 지정 현황 및 사용 기준에 대한 비교분석

초록

This study presents a comparative analysis of Korea’s regulatory framework and classification system for phosphate-based food additives in relation to international standards. Phosphates are multifunctional additives commonly used in foods for pH regulation, moisture retention, and mineral fortification. Korea permits 29 phosphate compounds, whereas other countries allow between 23 and 46, depending on their regulatory approaches. Korea, China, and Australia adopt the International Numbering System (INS) established by CODEX, while the European Union applies the E-number system. These differences have resulted in variations in the number of approved substances and their permitted uses. Notably, Korea allows all designated phosphate additives across all food categories, in contrast to most countries that impose food-type-specific restrictions. Such disparities reflect underlying differences in food culture, industrial practices, and safety evaluation systems. This study underscores the need for scientifically grounded and internationally harmonized classification standards to enhance regulatory clarity and promote global consistency.

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