Classification
Product TypeIngredient
Product FormPowder
Industry PositionFood Additive (Colorant) Ingredient
Market
In the United States, copper-complex chlorophyll derivatives used as food colorants are tightly regulated as FDA-listed color additives rather than GRAS substances. The FDA listing for sodium copper chlorophyllin (a copper-complex chlorophyll derivative) permits use only for coloring citrus-based dry beverage mixes, with a maximum level of 0.2% in the dry mix, and requires conformance to identity and purity specifications. This creates a niche, formulation-specific market where regulatory fit (intended use, dosage, and spec compliance) is the primary commercial constraint. Imports can enter the U.S. market, but are subject to FDA import controls such as prior notice, and FDA may detain non-compliant shipments.
Market RoleDomestic consumption market with a narrowly permitted, regulation-driven niche use profile for copper-complex chlorophyll color additives
Domestic RoleSpecialty green color additive for permitted food applications (not a general-purpose food color in the U.S.)
Specification
Primary VarietySodium copper chlorophyllin
Compositional Metrics- Moisture: not more than 5.0%.
- Solvent residues (acetone, ethanol, hexane): not more than 50 ppm singly or in combination.
- Total copper: not less than 4% and not more than 6%.
- Free copper: not more than 200 ppm.
- Lead (as Pb): not more than 10 ppm.
- Arsenic (as As): not more than 3 ppm.
- Mercury (as Hg): not more than 0.5 ppm.
- Absorbance ratio (405 nm / 630 nm): not less than 3.4 and not more than 3.9.
- Total copper chlorophyllins: not less than 95% of the sample (dried at 100°C for 1 hour).
Supply Chain
Value Chain- Plant-source chlorophyll extraction (alfalfa) → saponification and copper complex formation → purification and drying → quality testing against 21 CFR specifications → packaging and lot identification → distributor → beverage-mix manufacturer formulation use (citrus-based dry mixes only).
Temperature- Moisture control is operationally important because the U.S. listing specification includes a maximum moisture limit.
Freight IntensityLow
Transport ModeMultimodal
Risks
Regulatory Compliance HighU.S. food use is narrowly limited: sodium copper chlorophyllin is permitted to color citrus-based dry beverage mixes only, with a maximum of 0.2% in the dry mix; use outside this scope or above the limit can make the finished food non-compliant and trigger FDA enforcement actions (including import detention/refusal for imported product).Contractually lock the intended use (citrus-based dry beverage mixes) and maximum dosage into customer specifications; implement pre-shipment label/claims and formulation checks, and maintain documentation tying each lot to the applicable 21 CFR listing and compliant use level.
Food Safety MediumThe listing regulation includes strict limits for heavy metals (e.g., lead, arsenic, mercury) and copper-related parameters (total/free copper); out-of-spec lots can create recall and detention risk.Require lot-specific COAs referencing 21 CFR 73.125 specifications and verify with periodic third-party testing for heavy metals and copper parameters.
Documentation Gap MediumAt import or during customer audits, mismatches between product identity (e.g., 'chlorophylls copper complexes' vs. the specific FDA-listed name/spec) and the intended-use statement can trigger delays, holds, or rejection.Standardize nomenclature across commercial invoices, specs, and labels to the FDA-listed identity (as applicable) and attach an intended-use statement plus the relevant 21 CFR citation in the shipping dossier.
Logistics LowPort-of-entry holds and sampling can extend lead times and disrupt just-in-time formulation schedules, even when the product itself is not highly perishable.Plan buffer inventory for regulated additives and use compliant, complete documentation to reduce the probability of FDA holds.
FAQ
What food use is permitted for sodium copper chlorophyllin in the United States?Under the U.S. listing for sodium copper chlorophyllin, it may be used to color citrus-based dry beverage mixes only, and the amount in the dry mix must not exceed 0.2%.
Does sodium copper chlorophyllin require FDA batch certification before it can be used in food?No. The U.S. regulation for sodium copper chlorophyllin states that batches are exempt from FDA color additive certification, but the material still must meet the identity, purity, and use limitations in its listing regulation.
How can a U.S. food label declare this type of color additive?U.S. labeling rules for added color allow many certification-exempt color additives to be declared as 'Artificial Color,' 'Artificial Color Added,' or 'Color Added,' or alternatively as 'Colored with' followed by the listed color additive name, depending on the applicable regulation.