Plant-derived carbon black is not the same as plant-based activated carbon; let’s set the record straight about plant carbon black.

I. Requirements for the Food Additive Vegetable Carbon Black

The scope of the “National Food Safety Standard for the Food Additive Vegetable Carbon Black” (GB 28308-2012), issued on April 25, 2012 and effective June 25, 2012, stipulates that this standard applies to vegetable carbon black—a food additive produced by carbonization and refining from plant-based raw materials.

Physicochemical items and indicators specified in the national standard:

Loss on drying, w/% ≤ 12.0;

Carbon content (on a dry basis), w/% ≥ 95;

Ash content, w/% ≤ 4.0;

Alkali-soluble coloring substances were determined by testing;

High-grade aromatic hydrocarbons are determined by testing;

Total arsenic (expressed as As) / (mg/kg) ≤ 3;

Lead (Pb) / (mg/kg) ≤ 10;

Cadmium (Ge)/(mg/kg) ≤ 1;

Mercury (Hg) / (mg/kg) ≤ 1.

　　Plant-derived carbon black that meets the aforementioned standards may be used as a food additive, provided that a refining process is employed.

II. Proper Use of Vegetable Carbon Black in Food

At present, the use of food additives in China is governed by the National Food Safety Standard for the Use of Food Additives (GB 2760-2014), which came into effect on May 24, 2015.

　　Plant carbon black that meets the requirements of the National Food Safety Standard for Food Additives—Plant Carbon Black (GB 28308-2012) may be used as a food additive colorant (natural edible black pigment).

　　In accordance with the National Food Safety Standard for the Use of Food Additives (GB 2760-2014) and Announcement No. 8 of 2016 issued by the former National Health and Family Planning Commission, the food additive vegetable carbon black may be used in six categories of food: frozen beverages (excluding edible ice), baked goods, biscuits, confectionery, tapioca pearls, and collagen casings. Specifically, the maximum usage levels are as follows: 5.0 g/kg for frozen beverages (excluding edible ice), baked goods, biscuits, and confectionery; 1.5 g/kg for tapioca pearls; and collagen casings, where the amount added shall be limited to that required by the production process.

　　The definition of a variety shall be determined according to the following categories and interpretations:

03.0 Frozen beverages (excluding edible ice, 03.04): Includes 03.01 ice cream and popsicles; 03.03 flavored ice and ice lollies.

05.02 Confectionery: Includes hard candies, crisp candies, caramel candies, milk candies, tablet candies, gel candies, aerated candies, gum-based candies, and other types of confectionery.

06.05.02.04 Tapioca pearls: Round, non‑ready‑to‑eat products manufactured from starch through a granulation process.

07.02 Pastry: Foods made primarily from grain, oil, sugar and/or sweeteners, eggs, and other ingredients, with appropriate auxiliary materials added, and produced through processes such as shaping and cooking. This category includes: 07.02.01 Chinese-style pastries (excluding mooncakes), 07.02.02 Western-style pastries, 07.02.03 mooncakes, and 07.02.04 decorated pastries.

07.03 Biscuits: Includes filled and decorated biscuits, wafers, egg rolls, and other types of biscuits.

16.03 Collagen sausage casing.

　　In the processing of the aforementioned food categories, plant‑based carbon black may be used in accordance with the provisions of the National Food Safety Standard for the Use of Food Additives (GB 2760‑2014) and the announcements issued by the former National Health and Family Planning Commission. The maximum permitted levels are: 5.0 g/kg for frozen beverages (excluding edible ice), pastries, biscuits, and confectionery; 1.5 g/kg for tapioca pearls; and collagen casings, added at levels consistent with production needs.

　III. Differences Between Plant-Based Carbon Black and Bamboo Charcoal

Plant-derived carbon black is produced from plant stems and husks through carbonization and subsequent refining.

Food additive vegetable carbon black is a type of vegetable carbon black that complies with the requirements of the National Food Safety Standard for Food Additives—Vegetable Carbon Black (GB 28308-2012) and may be used as a food‑grade colorant. This standard applies to vegetable carbon black produced from plant‑based raw materials through carbonization and purification. In other words, vegetable carbon black can be manufactured using bamboo as one of its raw materials.

　　Bamboo charcoal is produced by carbonizing bamboo; its numerous micropores significantly increase its surface area. It is precisely this porous structure and large surface area that give bamboo charcoal excellent adsorption properties, making it suitable for applications such as water purification, air cleaning, and deodorization. In the production of bamboo charcoal, the carbonization process differs to some extent from that used to produce vegetable carbon black. More importantly, bamboo charcoal typically lacks a refining step, so its quality parameters may not meet the requirements of the National Food Safety Standard for Food Additives—Vegetable Carbon Black (GB 28308‑2012). Therefore, bamboo charcoal is not necessarily vegetable carbon black; only vegetable carbon black derived from bamboo through carbonization and subsequent refining, and compliant with the specifications set forth in GB 28308‑2012, qualifies as a food additive. The use of bamboo charcoal in food production that does not comply with the national food safety standards constitutes a violation, and thus ordinary bamboo charcoal should not be employed in food manufacturing, as this could amount to illegal additive practices.

IV. Proper Positioning of Plant-Derived Carbon Black

　　Plant-derived carbon black can be used as a food additive and colorant in food production, classified as an edible melanin.

On November 4, 2008, the General Office of the Ministry of Health issued a reply regarding whether bamboo charcoal may be used as a food ingredient or additive. Bamboo charcoal is not listed in the “Hygienic Standard for the Use of Food Additives” (GB 2760). As the submitted document did not provide detailed information on the production process, quality specifications, or other relevant details of bamboo charcoal, it is difficult to determine whether it qualifies as a common food ingredient, nor can it be ascertained whether this material is plant‑derived carbon black or plant‑based activated carbon. According to the “Hygienic Standard for the Use of Food Additives,” plant‑derived carbon black may be used as a coloring agent in the manufacture and processing of candies, rice products, wheat flour products, pastries, and biscuits; plant‑based activated carbon may be employed as a processing aid in the food industry, provided that it is removed prior to the final product’s completion.

　　Bamboo can be used as a raw material to produce the food additive “vegetable carbon black.” Enterprises must obtain a production license for this food additive, and their products must comply with the relevant food safety standards (GB 28308‑2012). Zhejiang Wanglin Biotechnology Co., Ltd. has already obtained such a license, and its products may be used in the manufacture of food items specified in the National Food Safety Standard for the Use of Food Additives (GB 2760‑2014).

V. Plant-derived carbon black is neither a health supplement nor a pharmaceutical product.

　　Plant-derived carbon black is neither a health supplement nor a pharmaceutical product. Products such as bamboo‑charcoal peanuts, bamboo‑charcoal bread, and bamboo‑charcoal cakes—made with bamboo charcoal as an ingredient—are marketed with claims of “detoxification and skin beautification,” which are inappropriate.

Food labels shall be appropriately labeled.

First, the food names are reasonable and standardized, such as “Plant-Based Charcoal Black Biscuits,” “Plant-Based (Bamboo) Charcoal Black Mooncakes,” “Plant-Based (Bamboo) Charcoal Black Candies,” “Plant-Based (Bamboo) Charcoal Black Ice Cream,” “Plant-Based Charcoal Black Popsicles,” “Black Popsicles,” and “Plant-Based Charcoal Black Tapioca Pearls,” among others.

The ingredient list should use appropriate names for the raw materials; terms such as “vegetable carbon black,” “vegetable carbon black (derived from bamboo),” or “(bamboo-based) vegetable carbon black” are permissible. However, the product description must not make claims regarding its functions or pharmacological effects.

Applications of Plant-Derived Carbon Black Abroad

The Joint FAO/WHO Expert Committee on Food Additives (JECFA), established under the World Health Organization (WHO) and the Food and Agriculture Organization of the United Nations (FAO), is currently the most authoritative international body for setting standards on food additives. The vast majority of the nearly 3,000 approved food additive standards worldwide are based on JECFA’s recommendations. JECFA does not set a maximum daily intake limit for vegetable carbon black (see Announcement No. 8 of 2016 issued by the former National Health and Family Planning Commission, which approved “the expanded scope of use for vegetable carbon black: collagen casings, added according to production needs”).

Regulation (EC) No 231/2012 of the European Union approves vegetable carbon black as a natural food colorant, with the EU food additive code E153. Vegetable carbon black is the most widely used in the EU, permitted in 67 major food categories, with virtually no restrictions on its level of use—its addition is governed solely by production needs. In Japan’s Food Additives List, vegetable carbon black is designated as “vegetable carbon pigment,” and it enjoys a broad scope of application; it is prohibited only in four specific food categories, while its use is otherwise unrestricted, typically added at levels dictated by manufacturing requirements. Canada, Mexico, Australia, Russia, India, Indonesia, and many other countries in Eastern Europe, South America, Southeast Asia, the Middle East, and elsewhere generally permit the use of vegetable carbon black, with usage limits and application rates aligned with the EU’s E153 standard. China’s national standard for the food additive vegetable carbon black, GB 28308–2012, is fully consistent with the EU’s E153.

Currently, the United States is the only country in the world that has not approved vegetable carbon black for use in food. Why has the U.S. FDA yet to grant such approval? This is related to the FDA’s regulatory framework and procedures: no U.S. company or research institution has submitted an application to the FDA seeking authorization for the use of vegetable carbon black in food, which is why the agency has not granted approval to date.

Finally, it is worth noting that plant‑derived activated carbon may be used as a processing aid in the food industry, primarily for adsorption and decolorization; it must be removed prior to the production of the final product, meaning no residual plant‑derived activated carbon should remain in the food. The United States likewise classifies plant‑derived activated carbon as a food‑industry processing aid and prohibits its consumption. However, medicinal charcoal tablets may be manufactured using plant‑derived activated carbon that meets pharmacopoeial standards, for use by patients. Please note that medicinal charcoal tablets are pharmaceutical products, not ordinary foods.