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MAHA Commission Releases Make Our Children Healthy Again Assessment

Yesterday, the Make America Healthy Again (“MAHA”) Commission released its highly anticipated Make Our Children Healthy Again Assessment (“Assessment”), which aims to examine “the root causes of deteriorating child health.”...more

HHS & FDA Request Public Comment to Inform Agency’s Infant Formula Nutrient Review

The U.S. Department of Health and Human Services (HHS) and U.S. Food and Drug Administration (FDA) are requesting public comment on nutrient requirements for infant formulas intended for healthy, full-term infants. FDA’s...more

HHS and FDA Announce Plans to Phase Out Certified Colors

On April 22, 2025, the U.S. Department of Health and Human Services (HHS) and U.S. Food and Drug Administration (FDA) announced a series of measures to phase out all certified colors from the nation’s food supply by the end...more

FDA Finalizes Two Food Allergen-Related Guidance Documents

On January 6, 2025, FDA published two final guidance documents related to food allergens: Questions and Answers Regarding Food Allergens, Including the Food Allergen Labeling Requirements of the Federal Food, Drug, and...more

FDA Issues “Phase II” Draft Guidance on Voluntary Sodium Reduction Targets

On August 15, 2024, the U.S. Food and Drug Administration (FDA) issued draft guidance with new, voluntary sodium reduction targets for foods, with the goal of reducing sodium intake to 2,750 milligrams (mg) per day from the...more

Food Law Preview - Key issues affecting the food industry in 2024

2024 is poised to be a big year for food regulation, particularly as federal agencies work to implement their regulatory agendas in preparation for a possible change in administration after the 2024 election. Here are the key...more

FDA Releases New Draft Guidance Chapter on Acidified Foods

In September 2023, FDA released two new chapters to its Hazard Analysis and Risk-Based Preventive Controls for Human Food (PCHF) Draft Guidance (Draft Guidance). New draft Chapter 11 is focused on food allergen programs, and...more

FDA releases draft guidance on food allergen programs under the Preventive Controls rule

The U.S. Food and Drug Administration (FDA) recently issued a new food allergen-focused chapter of its Hazard Analysis and Risk-Based Preventive Controls for Human Food draft guidance. The new chapter addresses allergen...more

FDA releases Draft Compliance Policy Guide for Major Food Allergen Labeling and Cross-contact

On May 16, 2023, the U.S. Food and Drug Administration (FDA) released a draft Compliance Policy Guide (CPG) for FDA staff regarding major food allergen labeling and cross-contact. The draft CPG would replace the existing...more

FDA Invites Comment on Petition Seeking to Repeal Color Additive Listing for Titanium Dioxide in Food

On April 14, 2023, the U.S. Food and Drug Administration filed a petition submitted by the Environmental Defense Fund (EDF) and several other NGOs requesting that the agency repeal its regulation authorizing the use of...more

A Seat at the Table | Hogan Lovells Monthly Food Digest - March 2023

Welcome to A Seat at the Table, Hogan Lovells Monthly Food Digest, where we share our thoughts and insights about some of the past month’s more notable developments when it comes to food regulation....more

FDA issues draft guidance setting action levels for lead in food intended for babies and young children

The U.S. Food and Drug Administration (FDA) issued a draft guidance for industry on Action Levels for Lead in Food Intended for Babies and Young Children (Draft Guidance). The proposed action levels would apply to processed...more

U.S. Food Law Preview - Key issues affecting the food industry in 2023

We’re a few weeks into 2023, and while some new year’s resolutions may have already fallen to the wayside, there are plenty of food law issues that will take us through 2023 and beyond. Here are key issues the Hogan Lovells...more

FDA completes first pre-market consultation for human food made with animal cell culture technology

The U.S. Food and Drug Administration (FDA) recently completed its first pre-market consultation for a human food made from cultured animal cells and issued a letter stating it had no further questions regarding the...more

Seafood companies voluntarily recall canned clam products after FDA finds concerning levels of PFAS

FDA recently released the results of its seafood survey it conducted to measure the amount of per- and polyfluoroalkyl substances (PFAS) in 81 seafood samples of clams, cod, crab, pollock, salmon, shrimp, tuna, and tilapia...more

FDA Issues Draft Guidance on Evaluating Public Health Impacts from Non-Major Food Allergens

The U.S. Food and Drug Administration (FDA) recently published draft guidance that explains the approach the agency intends to take when evaluating the public health importance of food allergens that are not one of the nine...more

FDA provides update on consumer research for voluntary “healthy” symbol

The U.S. Food and Drug Administration (FDA) has provided an update on the consumer research it plans to conduct on voluntary symbols that could potentially be used in the future to convey the nutrient content claim “healthy.”...more

USDA makes filing in lawsuit on BE food disclosure

USDA has filed its opposition to summary judgement in the case filed by the Center for Food Safety (CFS) regarding the agency’s implementation of the National Bioengineered Food Disclosure Standard (“BE rule”). As you may...more

FDA releases updated priority list of food guidance documents intended for publication by January 2023

The U.S. Food and Drug Administration’s (FDA’s) Center for Food Safety and Applied Nutrition (CFSAN) and Office of Food Policy and Response (OFPR) released an updated list of priority draft and final guidance documents...more

With the U.S. PFAS “Phase-out” clock ticking, what every food company should know

As regulatory bodies increase their scrutiny of per- and polyfluroalkyl substances (PFAS), food companies should work closely with their suppliers and prepare for the compliance transition....more

Federal Court Sides with FDA and Upholds GRAS Rule

The U.S. District Court for the Southern District of New York granted the U.S. Food and Drug Administration’s (FDA or the Agency) motion for summary judgment on September 30, 2021, against claims brought by a group of...more

The Ninth Circuit Court stayed the Proposition 65 Acrylamide Preliminary Injunction

We recently became aware of a 27 May 2021 opinion from the Ninth Circuit that “stayed” the preliminary injunction barring private parties from filing new lawsuits against businesses to enforce the Proposition 65 warning...more

FDA to test voluntary “healthy” symbols through consumer research

The U.S. Food and Drug Administration (FDA) has recently signaled its continued interest in developing a voluntary “healthy” symbol for packaged foods as a representation of the nutrient content claim....more

U.S. Congress passes the FASTER Act to require sesame allergen labeling

On 14 April 2021, the U.S. Congress passed the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act of 2021 (S. 578), which now heads to the White House for signature. ...more

Preliminary injunction issued against new Proposition 65 lawsuits for acrylamide in food & beverage

On 29 March 2021 the United States District Court for the Eastern District of California entered a significant ruling temporarily halting the filing of new lawsuits by the California Attorney General and anyone else related...more

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