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Food Manufacturers Food Labeling Regulatory Requirements

Shook, Hardy & Bacon L.L.P.

FDA Continues Dismantling "Recipe Approach" to Food Standards of Identity

U.S. Food and Drug Administration (FDA) food standards are experiencing the most activity in a generation, with FDA aiming to revoke 52 food standards followed by a proposal to revise the orange juice standard. If...more

Cozen O'Connor

FDA Encourages Food Manufacturers to Phase Out FD&C Red No. 3 Ahead of 2027 Deadline

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On July 14, 2025, the Food and Drug Administration (FDA) issued new guidance encouraging food manufacturers to phase out FD&C Red No. 3 ahead of the previous 2027 deadline and “as soon as is practicably possible.” Recall...more

Morgan Lewis - Well Done

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

Saul Ewing LLP

Marketing Risk in the Age of Wellness: When Are Food Claims Misbranding?

Saul Ewing LLP on

On October 1, 2024, the U.S. Food and Drug Administration (FDA or the Agency) implemented its unified Human Foods Program (HFP). The Agency established the HFP – which represented the single largest reorganization in FDA’s...more

Morgan Lewis - Well Done

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

McDermott Will & Schulte

Bye-bye, bright dyes: Strategies for responding to FDA’s synthetic food dye phase-out

On April 22, 2025, the US Food and Drug Administration (FDA) and the US Department of Health and Human Services (HHS) announced a plan to phase out petroleum-based synthetic dyes from the US food supply by the end of 2026,...more

Kelley Drye & Warren LLP

MAHA Movement Continues to Invite Significant Change for Food Regulation at Federal and State Levels

Robert F. Kennedy Jr. promised big changes as Secretary of the Department of Health & Human Services, the sweeping agency that oversees FDA, NIH, CDC, and other divisions and agencies. Five months into his tenure, he has...more

Holland & Knight LLP

Out with the Old: FDA to Revoke 52 Standards of Identity – What Food Companies Need to Know

Holland & Knight LLP on

The U.S. Food and Drug Administration (FDA) announced a final rule on July 16, 2025, revoking 52 standards of identity (SOIs) for food products that it deems obsolete. The FDA currently maintains more than 250 SOIs, and this...more

Akin Gump Strauss Hauer & Feld LLP

FDA Green Lights Another Natural Food Color

This week, the U.S. Food and Drug Administration (FDA) granted another color additive petition, approving the use of Gardenia (Genipin) in various food and beverage products. This marks the fourth naturally-derived color...more

DLA Piper

States Move Ahead With MAHA Agenda for Ultra-processed Food

DLA Piper on

As the Trump Administration considers what actions to take in response to its May 22, 2025 Make Our Children Healthy Again (MAHA) Assessment, state legislatures are taking action to regulate what they consider...more

Hogan Lovells

What’s next for UK HFSS regulation?

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First introduced in 2007 and ramping up in the last few years, several restrictions have been put in place in the UK to limit the promotion and advertising of food and drink products that are high in fat, sugar or salt...more

Womble Bond Dickinson

An Increasing Regulatory Maze for Nontraditional Meat Products

Womble Bond Dickinson on

As this blog has previously covered, various states have passed laws prohibiting plant-based products from being labeled like traditional meat products. A recent Oklahoma law bans using terms like beef, chicken, or bacon to...more

Morgan Lewis - Well Done

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

Holland & Knight LLP

Food For Thought: Texas Enacts Food Product Warning Labels for 44 Chemical Ingredients

Holland & Knight LLP on

Texas Gov. Greg Abbott on June 22, 2025, signed Senate Bill 25 (SB 25), a law that, among other provisions, requires the following consumer warning labeling on foods containing any of 44 ingredients: "WARNING: This product...more

Morrison & Foerster LLP

Newly Enacted Food Ingredient Disclosure Laws: Texas and Louisiana Reshape Food Labeling Compliance Landscape

In June 2025, Texas and Louisiana each enacted legislation mandating new label disclosures for foods containing a number of food and color additives, raising federal preemption and First Amendment questions. Both states have...more

American Conference Institute (ACI)

[Virtual Conference] Food Law and Regulation Boot Camp - July 22nd - 23rd, 8:15 am - 2:00 pm CST

Food laws and regulations are evolving rapidly — you and your team must prepare now to navigate the changes and anticipate what’s next on the horizon. ACI's virtual Food Law and Regulation Boot Camp will equip you with the...more

Greenberg Glusker LLP

Court Finds Requiring Prop. 65 Warnings for Acrylamide in Food is Unconstitutional

Greenberg Glusker LLP on

On May 2, 2025, the U.S. District Court for the Eastern District of California issued a landmark ruling in California Chamber of Commerce v. Bonta, Case No. 2:19-cv-02019, holding that Proposition 65 (“Prop. 65”) warning...more

Greenberg Glusker LLP

Judicial Burn: Court Declares Proposition 65 Acrylamide Warning Unconstitutional

Greenberg Glusker LLP on

Acrylamide, a Proposition 65-listed substance that naturally forms in the cooking and heating of many plant-based foods, has been the focus of court action over the past six years. However, companies will no longer be...more

Sheppard Mullin Richter & Hampton LLP

Navigating the Legal Soup: A New “Short-Form” Recipe for Prop 65 Warnings on Food and Beverages

Until this year, food companies—often the target of Proposition 65 enforcement actions—have been limited to specific “full-length” language for Prop 65 warnings, without explicit guidance regarding whether short-form warnings...more

Clark Hill PLC

The Learned Concierge - May 2025, Vol. 19

Clark Hill PLC on

Welcome to your monthly legal insights on the trends impacting the Retail, Hospitality, and Food & Beverage Industries. Alcohol Law - New Colorado Law Limits Grocery Stores’ Ability to Sell Hard Alcohol - Michael...more

Morgan Lewis - Well Done

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

Davis Wright Tremaine LLP

Flurry of Activity from FDA in the First Four Months of 2025

It is an understatement to say the last four months have been a whirlwind. Cabinet confirmations, executive orders, policy changes, and more, including some developments that impact (or that will impact) the food industry...more

Venable LLP

Healthy or Not? FDA Explains New Standards in Latest Webinar

Venable LLP on

On April 10, 2025, the Food and Drug Administration (FDA) released a pre-recorded webinar outlining the updated "healthy" nutrient content claim rule. As we previously discussed, the rule will go into effect on April 28,...more

Schwabe, Williamson & Wyatt PC

Regulatory Changes Address Surge of Food-As-Health Initiatives and Shift “Healthy” ‎Standard; Plus New Labeling Requirements

Food and beverage products that promote health and well-being have proliferated. Demand has surged for foods and drinks that are loaded with nutrients and offer health benefits. Their growth is partly driven by an increased...more

Womble Bond Dickinson

New FDA Criteria for Labeling Food as "Healthy"

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All of us have probably had the experience of browsing the aisles at the grocery store looking for healthy foods to take home for our families. A few foods we find may include the word “healthy” on the packaging. Did you know...more

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