Objective. We compared the European legislation on food additives, flavorings and enzymes with the Ukrainian one and formulated the main risks for human health in the context of the changes in the Ukrainian legislation connected with the regulation of food additives, flavorings, enzymes.
Materials and methods. The analysis of the scientific literature and the Ukrainian and international normative acts as well, concerning the safety and regulation of food additives, flavorings, enzymes.
Results. The main changes, implemented in the legislation of Ukraine, concerning the regulation of food additives, flavorings and enzymes, and entered into force on 20.09.2015, are the Law of Ukraine "On Basic Principles and Requirements for Safety and Quality of Food Products" and amendments to the Law of Ukraine "On Ensuring of Sanitary and Epidemiological Well-Being of the Population".
The law provides for the registration of sanitary measure objects by the central body of the executive power which creates and ensures the implementation of state policy in the sphere of public health. Automatic including of the permitted food additives, permitted in the EU, is provided in the domestic registry. The above norm deprives Ukraine of the sovereign right to determine the security requirements to the objects of the environment of human vital activity. According to the EU Regulation 1333/2008, 325 food additives were included in the list of the permitted. In Ukraine 264 food additives were included in “The List of Food Additives Approved for Use in Foods”. Thus, 115 food additives are introduced in the State Register of Ukraine without scientific justification and even without toxicological dossier for them. It should be noted that more stringent standards were set for certain food additives in Ukraine. In case of flavorings, the implementation of the Law entails the adoption of the list of the aromatic substances of about 3000 denominations without scientific justification and evaluation. As for enzymes, at present the European register of food enzymes has not been formed yet.
It should be noted that it is simply impossible to use the international normative-legal basis in mentioned sphere without adequate procedure for its harmonization and adaptation to the domestic conditions. Performing the harmonization of the Ukrainian legislation with the international one, it is inadmissible to reduce a level of the protection of public health adopted in the country.
Conclusions/ The main risks for the health of the population in the context of changes in the legislation of Ukraine concerning the regulation of food additives, flavorings, enzymes are: harmonization without scientific justification, incomplete adaptation of the European legislation and new regulator (the competent authority) which is not able yet to implement all its powers for the implementation of state policy in the sphere of security and separate indicators of food quality in full.

food additives, flavorings, enzymes, safety, risks, harmonization.

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2. Zakon Ukrainy “Pro ratyfikatsiiu Protokolu pro vstup Ukrainy do svitovoi orhanizatsii torhivli” [Law of Ukraine “On the Ratification of the Proceedings on the Entry of Ukraine in the World Trade Organization]. In : Vidomosti Verkhovnoi Rady Ukrainy [Gazette of the Supreme Soviet of Ukraine]. 2008 ; 23 : 213 (in Ukrainian).

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4. Pro zatverdzhennia pereliku kharchovykh dobavok, dozvolenykh dlia vykorystannia u kharchovykh produktakh : postanova Kabinetu Ministriv Ukrayiny № 12-99 [On the Adoption of the List of Food Additives Allowed for Use in the Foodstuffs : Resolution of the Cabinet of Ministers of Ukraine № 12-99]. (in Ukrainian). Available at : http://zakon5.rada.gov.ua/laws/show/12-99-%D0%BF

5. Pro vnesennia zmin do pereliku kharchovykh dobavok, dozvolenykh dlia vykorystannia u kharchovykh produktakh : postanova Kabinetu Ministriv Ukrayiny № 342-2000 [On the Changes into the List of Food Additives Allowed for Use in the Foodstuffs : Resolution of the Cabinet of Ministers of Ukraine № 342-2000]. (in Ukrainian). Available at : http://zakon4.rada.gov.ua/laws/show/342-2000-%D0%BF

6. Sanitarni pravyla i normy po zastosuvanniu kharchovykh dobavok : nakaz Ministerstva okhorony zdorovia Ukrainy № 222-96 [Sanitary Rules and Norms on the Use of Food Additives: Resolution of the Ministry of Public Health of Ukraine № 222-96]. (in Ukrainian).Available at : http://zakon4.rada.gov.ua/laws/show/z0715-96

7. General Standard for Food Additives. CodexStan 192-1995.

8. CAC/GL 66-2008 (CAC/GL 66-2008 Guidelines for the Use of Flavorings).

9. REGULATION (EC) № 1331/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16.12.2008 Stablishing a Common Authorisation Procedure for Food Additives, Food Enzymes and Food Flavourings.

10. REGULATION (EC) № 1332/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16.12.2008 on Food Enzymes and Amending Council Directive 83/417/EEC, Council Regulation (EC) № 1493/1999, Directive 2000/13/EC, Council Directive 2001/112/EC and Regulation (EC) № 258/97.

11. REGULATION (EC) № 1333/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16.12.2008 on Food Additives.

12. REGULATION (EC) № 1334/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16.12.2008 on Flavorings and Certain Food Ingredients with Flavoring Properties for Use in and on Foods and Amending Council Regulation (EEC) № 1601/91, Regulations (EC) № 2232/96 and (EC) № 110/2008 and Directive 2000/13/EC.