Research report: Regulatory divergence in synthetic food dye governance in Mexico and its public health implications

A new comment article published in Discover Food on 27 October 2026 argues that Mexico’s regulatory handling of synthetic food dyes has drifted apart from other jurisdictions, leaving consumers in the country exposed to additives that comparable products sold in Europe no longer contain. The piece, authored by a team led by Jorge Vargas-Meza, examines how scientific uncertainty, exposure patterns and regulatory frameworks interact to shape policy, using Mexico as a case study of food governance under incomplete evidence.

Synthetic food dyes are widely used in processed and ultra-processed foods, particularly in products marketed to children such as sugary beverages, snacks and breakfast cereals. In Mexico, these products account for a substantial proportion of dietary intake, the authors note, contributing to exposure to additives that serve primarily cosmetic and commercial purposes rather than nutritional or technological necessity. The comment draws on a qualitative review of publicly available regulatory documents, comparative observations of product formulation across markets, and existing scientific literature, and explicitly does not attempt quantitative risk assessment or causal claims.

The regulatory backdrop in Mexico is central to the argument. Food additives are governed by the General Health Law and a Food Additives Agreement issued by the Ministry of Health, frameworks that define permitted additives and their conditions of use but do not require specific front-of-pack warnings for synthetic dyes. The 2020 modification of NOM-051-SCFI/SSA1-2010 introduced front-of-pack warning labels for products high in sugar, sodium, saturated fat, calories and trans-fat, yet no analogous labeling mechanism exists for synthetic dyes, including in products targeted at children. As a result, the authors write, consumers are not explicitly informed about the presence of these additives at the point of purchase.

A pivotal development came in May 2026, after the analysis underlying the comment had been conducted, when the Ministry of Health withdrew the authorisation of erythrosine, also known as Red No. 3, in foods, beverages and dietary supplements, granting manufacturers 24 months to reformulate. The decision followed a risk assessment by the national regulatory agency concluding that estimated dietary exposure in Mexico could exceed the acceptable daily intake. Notably, the authors stress, the measure was adopted on the basis of a domestic exposure assessment rather than through alignment with decisions taken in other jurisdictions, illustrating how national determinations depend on country-specific exposure data and on how the burden of uncertainty is allocated.

Available evidence indicates that the presence of additives in ultra-processed foods in Mexico has increased, particularly synthetic food dyes, acid regulators and flavor enhancers, with tartrazine reported as one of the most frequently used. A study of 217 products across categories such as cereals, salty snacks, sugary beverages and dairy products found that 52 percent contained either synthetic dyes or a combination of natural and synthetic dyes. The most commonly identified synthetic dyes included Yellow No. 5 and No. 6, found in 46 percent of products, Red No. 3 and No. 40 at 29 percent, Blue No. 1 and No. 2 at 20.3 percent, and caramel colorants Class III and IV at 21 percent. Approximately 30 percent of products contained at least one synthetic dye, 15.8 percent contained two, and 6.2 percent contained three or more, a pattern the authors say indicates potential cumulative exposure across commonly consumed categories.

Comparative observations suggest that formulation differs markedly across markets. In the same study, products from the United Kingdom and Switzerland showed lower reliance on synthetic dyes in comparable categories such as cereals and salty snacks. Of 31 products analysed in the United Kingdom, 15 contained only natural colorants, 15 contained no colorants, and one contained a combination of natural and synthetic colorants. In Switzerland, 21 of 27 products contained no colorants and the remaining six contained only natural colorants; no product contained synthetic colorants. Frequently used alternatives included beta-carotene, annatto extract, turmeric or curcumin, beetroot and paprika. The authors argue these differences are consistent with variation in regulatory approaches and incentives for reformulation rather than technological constraints, since manufacturers already produce reformulated versions of the same brands for European markets.

The health evidence itself is contested, and the comment devotes careful attention to that contest. Systematic reviews integrating human and animal studies have identified recurring associations between specific dyes, such as Yellow No. 5 and Red No. 40, and changes in activity and attention, especially among susceptible subgroups of children, though reported effect sizes are generally modest and findings are not consistent across all populations or exposure contexts. Uncertainties persist regarding causal mechanisms, dose-response relationships and real-world exposure levels. The authors contrast two expert appraisals produced within the same regulatory deliberation initiated by California Senate Bill 504: a review of FDA-certified colour additives, funded by the International Association of Color Manufacturers with two of its three authors consulting for the sponsor, found the neurobehavioural evidence inconsistent, effect sizes small, and effects observed at intake levels considerably greater than estimated dietary consumption, concluding the data do not establish a causal relationship. The assessment prepared for the California Office of Environmental Health Hazard Assessment, drawing on a substantially overlapping body of evidence, concluded that synthetic dyes can affect activity and attention in some children and that current acceptable daily intakes may not be adequately protective. Where an evidence base admits more than one defensible reading, the authors write, regulatory outcomes turn on how the burden of uncertainty is allocated and on who is positioned to make that allocation.

Exposure data add further nuance. Analytical surveys of certified dyes in foods commonly consumed by children show that individual dyes contribute widely differing shares of the acceptable daily intake depending on the food category. Erythrosine was detected in relatively few categories, contributing approximately 0.1 to 2 percent of the acceptable daily intake where present, while azo dyes accounted for 10 to 22 percent of the maximum acceptable daily intake in beverages, with Red No. 40 alone contributing 7 to 9 percent and being the most prevalent dye identified across all food categories analysed. Regulatory attention to Red No. 3 therefore addresses a comparatively minor contributor to children’s total dye intake, and beverages rather than confectionery or bakery products constitute the principal dietary source of exposure. This is directly relevant to Mexico, where sugary beverages are among the most frequently consumed ultra-processed food categories and where 52 percent of the beverages analyzed contained synthetic colorants or a combination of synthetic and natural colorants. No equivalent analytical survey has been conducted for the Mexican food supply, although a national exposure assessment informed the 2026 regulatory decision on erythrosine, and concentrations of dyes used in commercial products are proprietary and can be established only through direct laboratory analysis.

On policy, the authors suggest several avenues: evaluating front-of-pack labeling indicating the presence of synthetic dyes, building on existing NOM-051 frameworks; periodic reassessment of selected additives by independent experts, with the erythrosine decision providing a domestic precedent; policies addressing school food environments and marketing directed at children; and strengthened monitoring, enforcement and transparency regarding additive use and concentrations. They also flag economic considerations, noting that purchasing-power-adjusted household disposable income in Switzerland is approximately three times that of Mexico, that natural colorants are generally less stable to light, heat and pH variation and carry higher unit costs, and that policy design should incorporate phased implementation, ex-ante economic impact assessment and attention to price effects in lower-income households. A Mexico-headquartered multinational whose brands appeared prominently among products containing synthetic colorants has committed to eliminating artificial colorants across its global portfolio by the end of 2026, reports its daily-consumption portfolio has been free of artificial colorants since 2024, and describes progress during 2025 in its occasional-consumption lines.

The comment concludes that synthetic food dyes remain widely used in processed and ultra-processed foods in Mexico, including products frequently consumed by children, and that while available evidence suggests average exposure to individual dyes may fall within established acceptable daily intake thresholds, widespread presence and multi-product use raise ongoing questions about cumulative exposure and population-level risk. Limitations in exposure data, the absence of publicly available information on additive concentrations, and the lack of studies reflecting real-world consumption patterns complicate definitive risk assessment. The Mexican erythrosine decision, reached through a domestic exposure assessment rather than regulatory alignment, indicates that national authorities may arrive at different conclusions from the same underlying evidence base, and that the availability of country-specific exposure data is decisive in how such decisions are made.

Subject of Research: Regulatory divergence in synthetic food dye governance between Mexico and other jurisdictions and its public health implications

Article Title: Regulatory divergence in synthetic food dye governance in Mexico and its public health implications

Article References: Vargas-Meza, J., Larrañaga-Flota, A., Magaña-Carbajal, P., Contreras-Manzano, A., Moreno-Altamirano, L., & Calvillo, A. (2026). Regulatory divergence in synthetic food dye governance in Mexico and its public health implications. Discover Food, 6(1), Article 439. https://doi.org/10.1007/s44187-026-01291-3

Image Credits: AI Generated

DOI: 10.1007/s44187-026-01291-3

Keywords: synthetic food dyes, Mexico, erythrosine, ultra-processed foods, food regulation, front-of-pack labeling, acceptable daily intake, NOM-051, neurobehavioral outcomes, children's health, product reformulation, scientific uncertainty