Kathleen Sanzo on Food Manufacturers

New Texas Legislation on Color Additives – Takeaways for Industry

As we have previously discussed, state and federal government authorities are turning their attention toward artificial coloring in foods. Most recently, Texas Governor Greg Abbott signed into law SB 25 targeting the sale of...more

8/12/2025 / Consumer Protection Laws , Enforcement Actions , False Advertising , Food Labeling , Food Manufacturers , New Legislation , Regulatory Requirements , State Attorneys General , Texas , Warning Labels

Processed Food Industry in the Crosshairs: FDA and USDA’s Ultra-Processed Food Request for Information

Last week’s issuance of a request for information (RFI) in the Federal Register by the FDA and the US Department of Agriculture (USDA) marks the first step in the administration’s effort to address health concerns associated...more

7/31/2025 / Consumer Protection Laws , Food and Drug Administration (FDA) , Food Labeling , Food Manufacturers , Food Safety , Popular , Public Health , Regulatory Requirements , USDA , Warning Labels

FDA Updates Food Labeling Compliance Program: What It Means for Food Manufacturers

In June 2025, the US Food and Drug Administration (FDA) announced a major update to its General Food Labeling Requirements Compliance Program—the first overhaul of this program since 2010. This program guides FDA inspectors...more

7/8/2025 / Class Action , Enforcement Actions , Food and Drug Administration (FDA) , Food Labeling , Food Manufacturers , Imports , New Regulations , Product Labels , Regulatory Requirements

FDA Proposes New Tool for Post-Market Scientific Assessment of Food Ingredients

On June 18, 2025, FDA announced for public comment a Post-market Assessment Prioritization Tool (Prioritization Tool) as an enhanced systematic process for post-market scientific assessment of chemicals in food, including...more

6/30/2025 / Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Public Comment , Regulatory Reform , Risk Assessment , Risk Management , Supply Chain , Toxic Chemicals

Food for Thought Implications of FDAs New Chemical Review Program

The US Food and Drug Administration recently announced a major initiative to strengthen oversight of food additives and other food-related chemicals. The agency described this as a “stronger, more systematic review process”...more

5/29/2025 / Chemicals , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , New Regulations , Public Health , Regulatory Oversight , Regulatory Reform , Regulatory Requirements , Rulemaking Process

State Legislation on Color Additives in Food: Takeaways for Industry

Both state and federal government authorities have recently turned their attention toward artificial coloring in foods. The Food and Drug Administration (FDA) announced a series of measures in April 2025 to phase out all...more

5/15/2025 / California , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Manufacturers , New Legislation , Proposed Legislation , State Legislatures

Proposed Nutrition and Allergen Labeling Changes for Alcoholic Beverages: Key Takeaways

The Alcohol and Tobacco Tax and Trade Bureau (TTB) has published a pair of proposed rules that if finalized could significantly reshape alcohol beverage labeling in the United States. In a move aimed at improving transparency...more

4/29/2025 / Alcohol Beverage Control , Beverage Manufacturers , Disclosure Requirements , Food Labeling , Food Manufacturers , Proposed Rules , Public Health , Regulatory Requirements , U.S. Treasury

HHS Signals GRAS Reform: How Food Manufacturers Can Prepare Now

Ingredient suppliers and food manufacturers face an uncertain supply chain landscape in which “generally recognized as safe” (GRAS) self-determinations may be more closely scrutinized. The US Department of Health and Human...more

4/10/2025 / Department of Health and Human Services (HHS) , Food & Drug Regulations , Food Manufacturers , Food Safety , GRAS , Regulatory Oversight , Regulatory Reform , Regulatory Requirements , Supply Chain

The Future of Artificial Colors in the US Food Supply Is Not So Bright

Only weeks after being confirmed, the Department of Health and Human Services (HHS) secretary has advised food companies to remove artificial colors from their food products. He recently met with several major food brand...more

3/25/2025 / Department of Health and Human Services (HHS) , Dietary Supplements , Enforcement Actions , Federal Food Drug and Cosmetic Act (FFDCA) , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Public Health , Regulatory Agenda , Regulatory Requirements , State and Local Government

Navigating FDA from 2024 into 2025 Human Foods Program

FDA Restructures its Food Resources Although there were a number of significant new regulations, the most significant food industry change in 2024 was the overhaul of how FDA structures itself to regulate foods generally....more

1/27/2025 / Enforcement Actions , Final Rules , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , New Regulations , Public Health , Risk Management

Food Safety 3.0: FDA Implements Human Foods Program Alongside Long-Awaited Reorganization

On October 1, 2024, the US Food and Drug Administration (FDA) announced the implementation of its long-promised reorganization, with the establishment of the unified Human Foods Program (HFP). The HFP now oversees all FDA...more

10/25/2024 / Dietary Supplements , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety

The Horse Is Out of the Barn: FDA and AAFCO Memo of Understanding on Animal Feed Ingredients to Expire

The Association of American Feed Control Officials (AAFCO) and the US Food and Drug Administration (FDA) announced on August 2, 2024 that their long-standing Memorandum of Understanding (MOU) governing the development and...more

8/20/2024 / Animal Food , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Food Supply

That’s a Wrap: FDA Announces Phase-Out of PFAS in Certain Food-Packaging Materials

The US Food and Drug Administration (FDA) recently announced that manufacturers have completed the voluntarily phase-out of the use of certain per- and polyfluoroalkyl substances (PFAS) in grease-proofing agents for food...more

4/8/2024 / Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Hazardous Substances , PFAS , Product Packaging , Toxic Chemicals

Combining the ‘Ingredients’: FDA Reorganizes Human Foods Infrastructure Under a Single Leader

In a sizable step toward reorganizing the Human Foods Program (HFP or Program) to rehaul the US Food and Drug Administration’s (FDA’s) current food infrastructure to better coordinate the agency’s regulation of food products,...more

9/14/2023 / Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Food Supply

Salt-Shaking it Up: FDA Issues Proposed Rule to Allow Salt Substitutes in Standardized Foods

FDA has consistently pursued its aim of encouraging US consumers to eat less salt. As we have previously written, FDA issued a Voluntary Sodium Reduction guidance in October 2021 to support the reduction of average sodium...more

6/14/2023 / Comment Period , Dietary Guidelines , Food & Drug Regulations , Food and Drug Administration (FDA) , Food Labeling , Food Manufacturers , Nutrition Facts Labels , Proposed Rules , Regulatory Agenda , Regulatory Reform

A Sweet Deal: FDA Allows New Qualified Heart-Healthy Claim for High Flavanol Cocoa Powder

FDA recently announced it does not object to the use of certain qualified health claims regarding the relationship between the consumption of cocoa flavanols in high flavanol cocoa powder and a reduced risk of cardiovascular...more

5/2/2023 / Food and Drug Administration (FDA) , Food Labeling , Food Manufacturers , Food Marketing , Health Claims , Nutrition Facts Labels , Regulatory Agenda

Eat Your Greens: FDA Proposes New Definition for ‘Healthy’ Packaged Food Claims

The US Food and Drug Administration issued a proposed rule on September 29 setting forth new criteria for the labeling of food products with the nutrient content claim “healthy” intended to help consumers more easily navigate...more

9/30/2022 / Food and Drug Administration (FDA) , Food Labeling , Food Manufacturers , Food Marketing , Food Safety , Health Claims , Nutrition Facts Labels , Regulatory Agenda

FDA Outlines Evaluation Approach to Non-Major Food Allergens in Draft Guidance

Last week, FDA issued a draft guidance that outlines the agency’s proposed approach for evaluating the public health importance of food allergens other than the eight major food allergens identified by US law, which are milk,...more

4/27/2022 / Draft Guidance , Food and Drug Administration (FDA) , Food Labeling , Food Manufacturers , Food Safety , Food Supply , Nutrition Facts Labels

A Pinch of Salt, but No Pepper(ing) This Time: FDA Issues Voluntary Guidance on Sodium Reduction

FDA issued a Voluntary Sodium Reduction guidance in October 2021, aimed to help Americans reduce average daily sodium intake over the next two and a half years. The guidance suggests voluntary sodium reduction targets for...more

11/4/2021 / Food and Drug Administration (FDA) , Food Labeling , Food Manufacturers , Food Safety , Food Supply , Nutrition Facts Labels , Public Health , Regulatory Requirements

FDA Signs Domestic Mutual Reliance Agreements with Four States to Protect Food Supply

FDA recently entered into domestic mutual reliance (DMR) agreements with the states of California, Florida, Utah, and Wisconsin to help ensure the safety of domestic food production and distribution systems. FDA’s goal is to...more

10/13/2021 / Federal Food Drug and Cosmetic Act (FFDCA) , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Food Supply , FSMA , Life Sciences , Regulatory Oversight

USDA Bioengineered Food Disclosure Rule Goes Into Effect on January 1, 2022

The US Department of Agriculture’s (USDA) Agricultural Marketing Service (AMS) published a final rule on December 21, 2018, implementing the National Bioengineered Food Disclosure Standard (NBFDS). Beginning on January 1,...more

9/29/2021 / Agricultural Sector , Bioengineering , Disclosure Requirements , Final Rules , Food Labeling , Food Manufacturers , USDA

Food Labeling Modernization Act Reintroduced in Congress

Congress on August 3 introduced the Food Labeling Modernization Act of 2021 (H.R. 4917 or 2021 Bill), a bill that proposes to amend the Federal Food, Drug, and Cosmetic Act (FFDCA) to improve requirements related to summary...more

9/15/2021 / Federal Food Drug and Cosmetic Act (FFDCA) , Food and Drug Administration (FDA) , Food Labeling , Food Manufacturers , Importers , Interstate Commerce , Labeling , Proposed Amendments

Bipartisan Group of Senators Introduces Bill to Regulate Hemp and Hemp-Derived CBD in Food

US Senators Ron Wyden (D-Ore.), Rand Paul (R-Ky.), and Jeff Merkley (D-Ore.) introduced legislation on May 21 to ensure hemp-derived cannabidiol (CBD) is regulated by the US Food and Drug Administration (FDA) like other...more

6/2/2021 / Beverage Manufacturers , Cannabidiol (CBD) oil , Cannabis Products , Dietary Supplements , Food & Drug Regulations , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Health and Safety , Legislative Agendas , Marijuana , Plant Based Products , Regulatory Agenda , Regulatory Oversight

Chocolate Cicadas and Mealworm Mints: Will FDA Spit Out Guidance for Edible Insects?

The month of May was buzzing with good news for the edible insect industry, but this emerging food trend still faces regulatory uncertainty in the United States....more

5/28/2021 / CGMP , Federal Food Drug and Cosmetic Act (FFDCA) , Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Food Supply , GRAS , Regulatory Requirements

FDA’s Latest Initiatives Seek Input from Industry to Develop Food Traceability Tools

To enhance its food traceability objective through the use of technology that strengthens the food safety system, the US Food and Drug Administration (FDA) unveiled, on May 19, its latest initiative through which it hopes to...more

5/24/2021 / Food and Drug Administration (FDA) , Food Manufacturers , Food Safety , Food Supply , Recordkeeping Requirements

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