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Texas and Louisiana Enact Laws Requiring Warning Labels and QR Code Notices for Food Ingredients

The states of Texas and Louisiana have each enacted first-of-their-kind warning or notice labeling requirements for food ingredients, both of which pose significant issues of concern related to the First Amendment and federal...more

FDA Issues Final “Healthy” Rule

On December 19, 2024, the U.S. Food and Drug Administration (FDA) issued its long-awaited final rule updating the requirements for when the term “healthy” can be used as an implied nutrient content claim in food labeling. ...more

FDA Issues Draft Guidance on Labeling of Plant-Based Alternatives to Animal-Derived Foods

On January 6, 2025, the U.S. Food and Drug Administration (FDA) issued draft guidance on the labeling of plant-based alternatives to animal-derived foods. The draft guidance provides best practices for naming plant-based...more

FDA and USDA Request Information Related to Standardizing Food Date Labeling

The U.S. Food and Drug Administration (FDA) and the U.S. Department of Agriculture’s (USDA’s) Food Safety and Inspection Service (FSIS) recently announced a Request for Information (RFI) related to standardizing food date...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FDA Issues “Phase II” Draft Guidance on Voluntary Sodium Reduction Targets

On August 15, 2024, the U.S. Food and Drug Administration (FDA) issued draft guidance with new, voluntary sodium reduction targets for foods, with the goal of reducing sodium intake to 2,750 milligrams (mg) per day from the...more

USDA seeks information regarding revisions to digital disclosure option for bioengineered foods

The U.S. Department of Agriculture’s (USDA’s) Agricultural Marketing Service (AMS) has published a Request for Information (RFI) asking interested parties to submit comments regarding potential revisions to the current...more

USDA finalizes updates to List of Bioengineered Foods

The U.S. Department of Agriculture (USDA) Agricultural Marketing Service (AMS) has issued a final rule updating the List of Bioengineered Foods (the List) under the National Bioengineered Food Disclosure Standard (the...more

FDA continues work on consumer research on front-of-pack nutrition labeling

The U.S. Food and Drug Administration (FDA) published a second procedural notice regarding its plans to conduct consumer research on a front-of-pack (FOP) nutrition labeling scheme....more

FDA seeks comment on food labeling information in e-commerce

The U.S. Food and Drug Administration (FDA) is requesting comment on the availability of nutrition, ingredient, and allergen information online for packaged foods sold through online grocery shopping platforms.  FDA explains...more

FDA issues draft guidance on labeling of plant-based milk alternatives

On February 22, 2023, the U.S. Food and Drug Administration (FDA) issued a draft guidance document recommending that plant-based alternative milks that use “milk” in the name (e.g., “soy milk”, “almond milk,” “oat milk”), and...more

FDA to test front of pack nutrition labeling schemes through consumer research

The U.S. Food and Drug Administration (FDA) continues to explore the development of a standardized front of package (FOP) nutrition labeling scheme by conducting consumer research....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

USDA issues final rule strengthening oversight and enforcement of its organic regulations

The U.S. Department of Agriculture (USDA) Agricultural Marketing Service (AMS) has amended its organic regulations to strengthen oversight and enforcement of the National Organic Program (NOP). The final rule, which requires...more

Asking the wrong questions: Consumer surveys may not save deficient labeling cases

Food labeling class actions brought on behalf of allegedly deceived consumers have become increasingly commonplace, especially in hotbed jurisdictions like California, New York, and Illinois. Labeling cases are, not unlike...more

FDA proposes updated criteria for "healthy" claims in labeling

The Food and Drug Administration (FDA) has issued its proposed rule updating the definition of the implied nutrient content claim “healthy” for use in labeling. Under the proposal, to be considered healthy, a food would need...more

Court invalidates text message option under Bioengineered Food Disclosure Standard

A court has invalidated the portion of the U.S. Department of Agriculture’s (USDA’s) Agricultural Marketing Service’s (AMS’s) final rule implementing the National Bioengineered Food Disclosure Standard (BE Rule) that allows...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 issues final rule on sodium, whole grains, and fluid milk in school meals

USDA recently issued a final rule establishing transitional nutrition standards for sodium, whole grains, and fluid milk in school meals. The new standards will take effect for the 2022-2023 and 2023-2024 school year. USDA...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

FDA publishes new Q&A on “0 g Total Sugar” statements

The Food and Drug Administration (FDA) recently added a new Question and Answer to its website related to “0 g total sugars” label statements....more

FDA releases priority list of food guidance documents FDA intends to publish by June 2022

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

Reminder: Opportunity to comment on draft “healthy” symbols for FDA’s planned consumer research

The U.S. Food and Drug Administration (FDA) has released draft options for a new voluntary “healthy” symbol for packaged foods to depict the nutrient content claim. As previously noted, on 7 May 2021 the FDA issued a notice...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

FDA issues Final Guidance on use of “Potassium Salt” as an alternate name for Potassium Chloride

Last week the Food and Drug Administration (FDA) issued a Final Guidance document regarding the use of an alternate name for potassium chloride in food labeling....more

FDA issues draft guidance on voluntary disclosure of sesame when added as flavoring or spice

On 10 November 2020, the U.S. Food and Drug Administration (FDA) announced the availability of a draft guidance recommending that companies voluntarily declare sesame in the ingredient list when it is used as a “flavor” or...more

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