What Is Liquid Smoke? Smoke Flavouring Rules for Food Buyers

If you buy liquid smoke for a food product, the texts in this guide use each regulator's own terms, such as smoke flavouring in the EU, artificial smoke flavor in a US labelling rule and Perisa Asap in Indonesia. The guide summarises selected rules from those texts: how the EU and Indonesia define the product, whether it is authorised in the EU, how it is declared on a label, what EFSA concluded about the products it assessed and what to ask a supplier.

What Do Regulators Call Liquid Smoke?

In the EU, Regulation (EC) No 1334/2008 lists smoke flavourings as one of the categories a flavouring can be made of or consist of, alongside flavouring substances, flavouring preparations, thermal process flavourings, flavour precursors and other flavourings. Its Article 3(2)(f) defines a smoke flavouring by reference to three products defined in Regulation (EC) No 2065/2003: primary smoke condensates, primary tar fractions and derived smoke flavourings. Regulation 2065/2003 calls primary smoke condensates and primary tar fractions together "primary products". Regulation 2065/2003 defines derived smoke flavourings in Article 3(4).

In Indonesia, BPOM Regulation 13 of 2020 on flavouring food additives, as amended by BPOM Regulation 11 of 2021, lists Perisa Asap, smoke flavouring, among the five types of ingredient used to make a flavouring. It defines Perisa Asap as an ingredient for making a flavouring food additive that is obtained from hardwood, including sawdust, shells and woody plants (our translation of the opening of the definition).

In the United States, 21 CFR 101.22(h)(6) refers to "pyroligneous acid or other artificial smoke flavors", and the meat labelling rule at 9 CFR 317.2(j)(3) refers to "an artificial smoke flavoring or a smoke flavoring".

Singapore's Food Regulations describe smoked meat, in regulation 63, and smoked fish, in regulation 74, as products treated with salt and subjected to the action of smoke from wood free from paint or timber preservative, or treated with "natural smoke solutions, extracts and its identical synthetic equivalent".

Is Smoke Flavouring Still Authorised in the EU?

Article 4(2) of Regulation 2065/2003 says no person shall place on the market a smoke flavouring, or a food in or on which one is present, "if the smoke flavouring is not a primary product authorised in accordance with Article 6, or if is not derived therefrom, and if the conditions of use laid down in the authorisation in accordance with this Regulation are not adhered to". Article 6 provides for a list of primary products authorised "to the exclusion of all others", and Implementing Regulation (EU) No 1321/2013 lays that list down as the Union list.

According to Implementing Regulation (EU) 2024/2067, the authorisations of the ten listed primary products, coded SF-001 to SF-010, were valid from 1 January 2014 for 10 years and renewable on application. No renewal application was submitted for SF-007 and SF-010, and their authorisations expired on 1 January 2024. The Commission refused renewal for the other eight, and Regulation 2024/2067 deleted all ten entries from the Union list.

Article 2(1) of that Regulation sets transitional dates for foods containing SF-001, SF-002, SF-003, SF-004, SF-005, SF-006, SF-008 or SF-009 that comply with the provisions laid down for those primary products in the Union list before 21 August 2024. Such foods may continue to be placed on the market, and remain on it until their date of minimum durability or use by date, if they are placed on the market until 1 July 2029 for cheese and cheese products, meat, processed fish and fishery products and fish roe, with their sub-categories, or until 1 July 2026 for all other food categories. Under Article 2(2), preparations containing those products and not intended to be consumed as such may be placed on the market until 1 July 2029 for use in the food categories listed above, and until 1 July 2026 for all other food categories. The Regulation defines preparations as mixtures of smoke flavourings, or of one or more smoke flavourings with other food ingredients such as flavourings, food additives, enzymes or carriers, to facilitate their storage, sale, standardisation, dilution or dissolution. The 1 July 2026 date has passed.

Regulation 2024/2067 states that those ten products are no longer authorised. Our article on what counts as a natural flavour notes the same deletion in its section on the EU Union list.

What Did EFSA Conclude About the Products It Assessed?

The European Food Safety Authority's Panel on Food Additives and Flavourings published opinions on 16 November 2023 on the renewal applications for SF-001, SF-002, SF-003, SF-004, SF-005, SF-006, SF-008 and SF-009, each submitted under Article 12(1) of Regulation 2065/2003. Each opinion covers the data submitted on the chemical characterisation, dietary exposure and genotoxicity of one primary product.

For SF-001, SF-002, SF-003, SF-005, SF-006 and SF-008, the Panel concluded that the primary product "raises concern with respect to genotoxicity". For SF-004, it concluded that the potential concern for genotoxicity "cannot be ruled out, until the genotoxic potential of both substances is clarified", referring to two substances in that product. For SF-009, it concluded that the potential safety concern for genotoxicity "cannot be ruled out". Both of those opinions state that, according to EFSA's guidance on smoke flavourings, the product's safety "has not been sufficiently demonstrated".

Regulation 2024/2067 refers to "the Authority's concerns" linked to the same eight products when it explains why it set transition periods.

How Is Smoke Flavouring Declared on a Label?

EU. Annex VII Part D of Regulation (EU) No 1169/2011 gives two designations for flavourings in the list of ingredients. One is "flavouring(s)" or a more specific name or description, if the flavouring component contains flavourings as defined in points (b) to (h) of Article 3(2) of Regulation 1334/2008, a range that includes smoke flavourings in point (f). The other is "smoke flavouring(s)", or "smoke flavouring(s) produced from food(s) or food category or source(s)", for example "smoke flavouring produced from beech", if the flavouring component contains smoke flavourings as defined in point (f) and imparts a smoky flavour to the food. The same Part says "natural" is used for flavourings in accordance with Article 16 of Regulation 1334/2008. Article 16(2) allows "natural" for a flavouring only if the flavouring component comprises only flavouring preparations and/or natural flavouring substances.

For flavourings not intended for sale to the final consumer, Article 15(1)(e) of Regulation 1334/2008 requires the packaging or containers to list, in descending order of weight, the categories of flavourings present and the names of the other substances or materials, or their E numbers where appropriate. That list may appear instead on consignment documents supplied with or before delivery, provided "not for retail sale" appears on an easily visible part of the packaging or container.

Singapore. For prepacked food, regulation 5 of the Food Regulations requires a label whose particulars include, for food of two or more ingredients, a list giving the appropriate designation of each ingredient other than a processing aid: a specific rather than generic name, except as the First Schedule provides. The First Schedule lets any flavouring be declared by the generic term "Flavour or flavouring, qualified by the words 'natural', 'nature identical' or 'artificial', or a combination of any of these words, if applicable". Our guide to declaring a flavouring on a Singapore label covers the generic term and the three qualifiers in more detail.

United States. Under 21 CFR 101.22(h)(6), pyroligneous acid or other artificial smoke flavors used as an ingredient in a food "may be declared as artificial flavor or artificial smoke flavor". The same paragraph bars any direct or implied representation that a food flavoured with them has been smoked or has a true smoked flavour, or that a seasoning sauce or similar product containing them and used to season or flavour other foods will result in a smoked product or one with a true smoked flavour. For meat food products, 9 CFR 317.2(j)(3) requires a statement such as "Artificial Smoke Flavoring Added" or "Smoke Flavoring Added", as may be applicable, in prominent letters next to the product name when either is added as an ingredient as permitted in part 318, and the ingredient statement must identify it.

Indonesia. BPOM Regulation 13 of 2020, as amended by BPOM Regulation 11 of 2021, groups flavourings as natural, nature identical or artificial. Its natural group consists of one or more natural flavouring substances, natural aromatic raw materials, flavouring preparations and/or Perisa Asap, and must not contain nature-identical or artificial flavouring substances; its nature-identical group may also contain Perisa Asap. For labelling, Pasal 14 groups flavourings as natural (Perisa Alami) or synthetic (Perisa sintetik), and the group must appear on the label as the name of the type of flavouring and in the ingredient lists of the flavouring and of the processed food. The 2021 amendment added Pasal 14(3a), which states that synthetic flavouring consists of nature-identical flavouring and artificial flavouring. Pasal 8 sets a maximum of 0.03 mcg/kg of benzo[a]pyrene in food products that use Perisa Asap; where the food product is already covered by the BPOM regulation on contaminants, the benzo[a]pyrene maximum follows that regulation's limits.

What Should You Ask a Supplier?

Which primary product does the smoke flavouring derive from, and what is its code? For the EU, Article 13 of Regulation 2065/2003 requires the operator who first places an authorised primary product, or a smoke flavouring derived from one, on the market to pass on the product's code, its conditions of use and, for a derived smoke flavouring, its quantitative relation to the primary product. Every later operator must pass the same information on.

Is it authorised in each market you sell into, and when was that checked? For EU sales, check the code against the current Union list. For a food containing one of the eight products named in Article 2(1), ask for evidence that it complies with the provisions laid down for that primary product in the Union list before 21 August 2024, and check its placing-on-the-market date against the deadline for its food category.

How should it be declared in each market? Ask for the EU designation under Annex VII Part D, the Singapore qualifier, the US designation together with the definition in 21 CFR 101.22(a) the supplier relies on, the statement for a US meat food product, and the Indonesian label group under Pasal 14.

For Indonesia, ask for the supplier's position on the Pasal 8 benzo[a]pyrene limit as it applies to your finished food.

For enquiries, contact our team.

Legal texts were read on 11 October 2026 in the versions listed in the sources. Indonesia's BPOM Regulation 13 of 2020 was read together with its amending BPOM Regulation 11 of 2021.

Is Liquid Smoke Still Allowed in the EU?

Implementing Regulation (EU) 2024/2067 deleted all ten smoke flavouring primary products, SF-001 to SF-010, from the Union list. Foods containing SF-001, SF-002, SF-003, SF-004, SF-005, SF-006, SF-008 or SF-009 that comply with the provisions laid down for those primary products in the Union list before 21 August 2024 may continue to be placed on the market, and remain on it until their date of minimum durability or use by date, if placed on the market until 1 July 2029 for cheese and cheese products, meat, processed fish and fishery products and fish roe, with their sub-categories, or until 1 July 2026 for all other food categories.

How Do I Declare Smoke Flavouring on an EU Ingredient List?

Annex VII Part D of Regulation 1169/2011 gives two designations. "Flavouring(s)" or a more specific name or description applies if the flavouring component contains flavourings in points (b) to (h) of Article 3(2) of Regulation 1334/2008, which include smoke flavourings. "Smoke flavouring(s)", or "smoke flavouring(s) produced from food(s) or food category or source(s)", such as "smoke flavouring produced from beech", applies if the flavouring component contains smoke flavourings as defined in point (f) and imparts a smoky flavour to the food.

What Did EFSA Conclude About the Products It Assessed?

In opinions published on 16 November 2023, EFSA's Panel on Food Additives and Flavourings assessed eight primary products whose renewal had been applied for. For six it concluded that the product "raises concern with respect to genotoxicity". For SF-004 it concluded that the potential concern for genotoxicity "cannot be ruled out, until the genotoxic potential of both substances is clarified", and for SF-009 that the potential safety concern for genotoxicity "cannot be ruled out"; both opinions state that the product's safety "has not been sufficiently demonstrated". Each opinion assesses one primary product.

How Does US Labelling Treat Artificial Smoke Flavor?

Under 21 CFR 101.22(h)(6), pyroligneous acid or other artificial smoke flavors used as an ingredient in a food may be declared as "artificial flavor" or "artificial smoke flavor", and no direct or implied representation may be made that a food flavoured with them has been smoked or has a true smoked flavour. Under 9 CFR 317.2(j)(3), when artificial smoke flavoring or smoke flavoring is added as an ingredient in the formula of a meat food product, as permitted in part 318, the label must show a statement such as "Artificial Smoke Flavoring Added" or "Smoke Flavoring Added", as may be applicable, in prominent letters next to the name of the product, and the ingredient statement must identify the flavoring added.