Classification
Product TypeIngredient
Product FormPowder / Crystals
Industry PositionFood Additive (Acidity Regulator / Sequestrant / Emulsifying Salt)
Market
Trisodium citrate (INS 331(iii), commonly labeled as E331(iii)) is a permitted food additive used as an acidity regulator, sequestrant and emulsifying salt in food manufacturing in Russia within the Eurasian Economic Union (EAEU) framework. Market access and labeling expectations are anchored in EAEU technical regulations for food additives (TR CU 029/2012) and food labeling (TR CU 022/2011), with conformity assessment and EAC marking requirements. Russia is present in reported international trade flows for HS 291815 (salts and esters of citric acid), including exports to neighboring markets, indicating active regional circulation for this product group. The dominant commercial constraint for this product–country pairing is sanctions-driven counterparty, payments, shipping and insurance friction, which can delay or prevent otherwise lawful trade.
Market RoleDomestic consumption market within the EAEU single market, with some regional exports (HS 291815 reported)
Domestic RoleIndustrial input for food manufacturing and formulation (buffering, chelation, emulsifying-salt applications) under EAEU food-additive rules
Specification
Physical Attributes- Colourless, odourless crystals or white crystalline powder (hydrated forms exist)
- Freely soluble in water; insoluble in ethanol
Compositional Metrics- JECFA specification includes an assay minimum of 99.0% on the dried basis (food additive specification reference)
Grades- Food additive grade aligned to Codex/JECFA specifications (buyer/importer specification dependent)
Supply Chain
Value Chain- Food-additive manufacture and QA (specification + CoA) → packaging → importer/distributor → industrial food manufacturer use
Freight IntensityMedium
Transport ModeMultimodal
Risks
Sanctions Compliance HighSanctions, export controls, and financial restrictions affecting Russia can block or delay payments, shipping/insurance, and trade services (including through risks tied to designated counterparties or ownership/control links), even when trisodium citrate itself is not a controlled item.Run end-to-end sanctions and beneficial-ownership screening; confirm banking/payment routes and logistics/insurance availability before shipment; obtain legal/compliance sign-off for the specific transaction structure.
Regulatory Compliance MediumNon-conformance with EAEU technical regulations for food additives and labeling (including required conformity assessment, EAC marking where applicable, and labeling conventions) can trigger border delays, refusal of release, or market-withdrawal actions.Align product dossier (specification/CoA) to recognized standards (e.g., JECFA) and validate labeling and conformity documentation against TR CU 029/2012 and TR CU 022/2011 before shipment.
Logistics MediumSanctions-driven changes in carrier availability, routing, and insurance can cause lead-time instability and higher landed costs for chemical food ingredients shipped into or within Russia/EAEU channels.Qualify multiple carriers/routes and build buffer lead time; contract with logistics providers experienced in sanctioned-jurisdiction compliance and documentation.
Labor & Social- Heightened human-rights and reputational risk screening linked to Russia’s war against Ukraine and the associated sanctions environment; counterparties and beneficial owners may be designated or otherwise restricted.
FAQ
What are the key regulations to consider when placing trisodium citrate on the Russian market?Russia applies Eurasian Economic Union (EAEU) rules for food additives and labeling. TR CU 029/2012 sets mandatory requirements for food additives (including circulation and labeling elements), while TR CU 022/2011 governs food labeling requirements that apply when the additive is used as an ingredient in a food product.
What is the single biggest trade risk for trisodium citrate transactions involving Russia?Sanctions and export-control compliance is the biggest deal-breaker risk. Even if trisodium citrate itself is not restricted, payment routes, shipping/insurance, and counterparties (including ownership/control links) can be blocked or delayed under US, EU, and UK sanctions frameworks.
What functional roles does trisodium citrate serve in food manufacturing?Codex GSFA lists trisodium citrate (INS 331(iii)) as an acidity regulator, emulsifier, emulsifying salt, sequestrant, and stabilizer. JECFA evaluations also recognize citrate salts as having a low toxicological concern at intended uses (ADI not specified).