CAS 77-92-9 · REACH · European Union

Citric acid under REACH

C6H8O7 · 柠檬酸

Status: Registered. Citric acid is fully registered under REACH at the highest tonnage band (>1,000,000 tonnes/year). Multiple lead registrants from the food-and-specialty-chemical industry consortium. Anhydrous and monohydrate forms share registration. Citric acid is also approved under EU Regulation (EC) No 1333/2008 as food additive E330 (acidulant, antioxidant, sequestrant), independent of REACH but operationally relevant for food-grade trade.

Citric acid is REACH-clean from a hazard standpoint but the EU price-undertaking arrangement (alternative to anti-dumping duty) is the practitioner-facing complexity that distinguishes the EU lane from the much-tougher US lane. Chinese producers can ship to EU under price-undertaking at competitive landed cost; the same producer faces 50-100%+ AD/CVD margins into the US. EU food-grade demand (Coca-Cola, Pepsi, Unilever, Nestle European operations) is the structural pull and supports premium pricing for E330-grade product. Industrial-grade demand for detergents and chelating agents is bulk-tonnage commodity. Two of the three top-3 global citric acid producers are Chinese (RZBC, Weifang Ensign), with COFCO Biochemical also in top-5; Chinese supply is structural to the EU market.

Listing and threshold

Substance Citric acid (CAS 77-92-9), C6H8O7
Regime EU Regulation (EC) No 1907/2006: Registration, Evaluation, Authorisation and Restriction of Chemicals
Jurisdiction European Union (EU-27 plus EEA: Iceland, Liechtenstein, Norway)
Status Registered
Tonnage threshold Registration required for any importer or manufacturer placing >1 t/year on the EU market

Classifications under this regime

  • Eye Irrit. 2 (causes serious eye irritation), H319
  • Skin Irrit. 2 (mild skin irritation), H315
  • NOT classified as Acute Tox., STOT, Carc., Muta., or Repr.
  • GHS pictograms: GHS07 (exclamation mark)
  • Signal word: Warning (not Danger)
  • NOT on the harmonised CLP Annex VI list (self-classified)
  • EU food-additive E330 status under Regulation (EC) No 1333/2008

Restrictions and conditions of use

  • NOT on REACH Annex XIV (Authorisation list)
  • NOT on REACH Annex XVII (Restriction list)
  • NOT classified as SVHC
  • NOT scheduled under EU Drug Precursors Regulation
  • NOT a regulated explosives precursor
  • EU food-additive purity criteria per Regulation (EU) No 231/2012 apply for food-grade product (heavy metals, sulfate ash, oxalate limits)
  • Active EU price-undertaking arrangement on Chinese-origin citric acid since 2008 (alternative to anti-dumping duty); minimum import price applies per producer

Importer obligations

A non-EU producer cannot register directly under REACH. The EU importer of record must hold a registration in their own name or rely on an Only Representative (OR) appointment. For citric acid specifically, the EU price-undertaking arrangement is the practitioner-facing layer that distinguishes the EU lane from the US lane; Chinese exporters under price-undertaking commit to a minimum CIF price into the EU and the arrangement avoids ad valorem duty if compliance is verified. Food-grade product requires additional EU food-additive E330 purity-criteria compliance.

Required documents

  • REACH registration number on the EU side (registrant or OR-appointed)
  • Safety Data Sheet (SDS) compliant with REACH Annex II in destination Member State language(s); brief because minimal hazards
  • Food-grade purity certificate per EU Regulation (EU) No 231/2012 (where food-grade)
  • EU price-undertaking compliance documentation (Chinese producer commits to minimum CIF price; broker verifies)
  • Customs entry with HS code 29181400 (citric acid)

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

  • EU price-undertaking is per-producer; not all Chinese producers are signatories. Non-undertaking producers face full anti-dumping duty (the price-undertaking alternative is voluntary)
  • Food-grade E330 requires lower heavy-metal and trace-impurity limits than industrial-grade
  • EU CBAM does NOT include citric acid in 2026 Phase 1 scope
  • EU food-grade certificates issued by Chinese laboratories may need EU-recognised cross-validation
  • Calcium-citrate intermediate impurity testing (legacy production process by-product) is occasionally requested by EU buyers

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for citric acid, see the CAS 77-92-9 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the citric acid cornerstone hub covers the full sourcing chain.

For the structure and history of REACH, see the REACH glossary entry.

Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.

Read next

Cross-jurisdiction profile and sourcing references

Referenced in

6 pages across the Sourzi moat

This term shows up in 4 regulatory pages, 1 topic clusters, 1 CAS profiles. Sample backlinks per content type below.

Regulatory (4)

Plus 1 more regulatory pages.

Topic cluster (1)

CAS (1)

Free download

Free PDF: the same MSDS verification template the Sourzi team uses to cross-reference factory documents against TSCA, REACH, AICIS, and CDR before booking.