Butylated hydroxytoluene (BHT) is the antioxidant the food industry lists as E321. In our table it is low risk: it takes 6 points off the additive subscore (about 2 of the 100).
- The key finding, from the FDA: FDA finalised its post-market chemical assessment programme on 2026-05-12 and selected butylated hydroxytoluene as one of the first two chemicals to reassess (with azodicarbonamide, E 927a). Not a ban, a phase-out or a safety finding, and it does not change this classification: BHT is currently under FDA post-market reassessment, so its US status is under active review rather than settled; this citation records that review (FDA news release 'FDA finalizes food chemical safety post-market assessment program, launches reassessment of BHT and ADA' (program finalized 2026-05-12))
- Flagged for young children. Set only where EFSA’s own exposure assessment shows toddlers or children exceeding or approaching the ADI, or where a regulator used explicitly child-specific language. For a child under 6 it moves up one class, to moderate risk.
- Where you meet it. It turns up in 5 of the 10,000 packaged foods scanned most on Open Food Facts, most often in margarines. Nine in ten of those foods are sold in Europe (counted 26 Sep 2026).
- 5 citations from the FDA, EFSA, IARC, peer-reviewed research and US state law, each one below.
What BHT does to a score
A packaged food's additive subscore starts at 100 and loses points for each additive on the label; that subscore is a third of the final score. BHT takes 6 points off the additive subscore (about 2 of the 100), and a child under 6 sees it one class higher again. Scan the pack in Sito and the score you get is the one for your own child's age, with this additive named in the reasons. How we score has the whole method.
See what is in your own cupboard
Scan a packaged food and Sito names the additives in it, then scores the product out of 100 for your child's age.
What the sources found
Every classification in our table comes from the citations below, and nothing else. Each finding is our one-line summary of what the source concluded, with the source and reference beside it.
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FDA
news release 'FDA finalizes food chemical safety post-market assessment program, launches reassessment of BHT and ADA' (program finalized 2026-05-12)
FDA finalised its post-market chemical assessment programme on 2026-05-12 and selected butylated hydroxytoluene as one of the first two chemicals to reassess (with azodicarbonamide, E 927a). Not a ban, a phase-out or a safety finding, and it does not change this classification: BHT is currently under FDA post-market reassessment, so its US status is under active review rather than settled; this citation records that review. -
EFSA
10.2903/j.efsa.2012.2588 (EFSA Journal 2012;10(3):2588)
ADI 0.25 mg/kg bw/day (NOAEL 25 mg/kg, UF 100); not of concern for genotoxicity. 'For exposure of children to BHT from its use as food additive ... it is also unlikely that this ADI is exceeded at the mean, but is exceeded for some European countries (Finland, The Netherlands) at the 95th percentile', while adults are unlikely to exceed it at mean or P95. -
IARC
classification list — Butylated hydroxytoluene (BHT), CAS 128-37-0, Group 3 (Vol. 40, Suppl. 7, 1987)
Not classifiable as to carcinogenicity to humans. -
Peer-reviewed
Liu & Mabury, Environ Int 2019; doi:10.1016/j.envint.2019.04.028; and Koch et al., Int J Hyg Environ Health 2020; doi:10.1016/j.ijheh.2020.113541
Human biomonitoring detects BHT and its metabolites in urine at population scale, confirming widespread internal exposure alongside dietary intake. -
US state law
TX SB 25, 89th Texas Legislature (2025)
BHT is among the 44 ingredients that would trigger a warning label from 2027-01-01; enforcement preliminarily enjoined 2026-02-11 (First Amendment). Not a ban.
Why this class
A credible adverse or precautionary signal that stops short of every Moderate and High criterion: peer-reviewed adverse findings not yet reflected in regulatory status, an exposure exceedance confined to high-percentile or single-event estimates, or a precautionary regulatory step short of those criteria, a reduced ADI, a data limitation noted without an adverse conclusion, a narrowed or conditioned authorisation, or a child-focused assessment or school-food law that covers the additive as part of a class.
Our confidence in this row's classification is high. Medium or low does not mean the evidence is weak; it means something about the row is still being pinned down, usually a regulatory status confirmed from one source rather than two.
Questions parents ask
Is BHT (E321) safe for kids?
Low risk. In Sito it takes 6 points off the additive subscore (about 2 of the 100). It is flagged for young children, so for a child under 6 it moves up one class, to moderate risk: 15 points off the additive subscore. The finding we rely on: FDA finalised its post-market chemical assessment programme on 2026-05-12 and selected butylated hydroxytoluene as one of the first two chemicals to reassess (with azodicarbonamide, E 927a). Not a ban, a phase-out or a safety finding, and it does not change this classification: BHT is currently under FDA post-market reassessment, so its US status is under active review rather than settled; this citation records that review (FDA news release 'FDA finalizes food chemical safety post-market assessment program, launches reassessment of BHT and ADA' (program finalized 2026-05-12)).
What is E321?
E321 is the E number for Butylated hydroxytoluene, an antioxidant. It is also called BHT. Open Food Facts tags it en:e321.
Next to it on the label
The E numbers either side of E321 in our table, then the closest antioxidants by number.
- Dodecyl gallate (E312), high risk
- Erythorbic acid (E315), no risk identified
- Sodium erythorbate (E316), no risk identified
- TBHQ (E319), low risk, flagged for young children
- BHA (E320), high risk
- Lecithins (E322), no risk identified