Changing Food Regulations: 3 Takeaways for Compliance Leaders

If you work in the food industry, you know the pace of regulatory change has picked up dramatically. From new state-level additive bans creating a complex map of compliance, to a federal push for front-of-pack labeling that will reshape packaging, the pressure on R&D, compliance, and labeling teams is immense. The challenge is clear: how do you stay ahead of this evolving landscape to ensure your products remain compliant, competitive, and trusted by consumers? 

Read More: The Great Reformulation: How the Food Industry is Adapting to Change 

That's the question we set out to answer during our recent webinar, The Great Reformulation: Stay Ahead of Evolving Food Regulations.  Trustwell's regulatory team leader, Megan Murphy, a registered dietitian and public health expert, broke down recent key changes, their driving factors, and how food industry leaders can prepare for future regulatory shifts.

New Food Regulations: What They Are, Where They're Coming From, and Why 

A convergence of factors drives this wave of new rules. As the food industry innovates with new products and alternatives, regulations have to change to keep pace.  Many of the FDA’s foundational standards of identity are decades old, created for a marketplace that looks very different from today’s.  

This push is also a direct response to public health trends and growing consumer demand for transparency.  As Megan Murphy explains, "The content of food is being evaluated based on the current state of health... and it could wrap into what consumers are looking for and what their point of view is and what they would like for their intake for health." 

State & Federal Food Additive Bans Can Create a Compliance Puzzle 

The long-standing model of a single, primary federal authority setting the rules is becoming more complicated. We are now in an era of multi-level regulation where federal agencies, state legislatures, and even international bodies are driving change simultaneously, forcing companies to track multiple moving targets. 

Historically, the FDA’s process for reviewing chemical safety was often reactive, responding to citizen petitions or new scientific evidence on a case-by-case basis. Now, the agency is adopting a more proactive stance. This new process includes reviewing chemicals that are no longer allowed in other countries and welcoming more stakeholder input. This shift has accelerated action on ingredients like Brominated Vegetable Oil (BVO) and Red Dye No. 3. 

At the same time, states are no longer waiting for federal guidance. Led by early bills in places like California and New York, a "cascade" of state-level legislation has emerged. The California Food Safety Act, for example, will ban four additives — brominated vegetable oil, potassium bromate, propylparaben, and Red Dye No. 3 — by January 1, 2027. Other states are following suit, and this can create a compliance puzzle for food companies.

As Megan Murphy notes, businesses must pay close attention to which regulation is stricter: "In general, federal laws invalidate or preempt a conflicting state law, but stricter state laws could still stand. The California date [for phasing out Red Dye No. 3] is sooner than the federal date. So, if someone is selling a product in California, they would have to meet the earlier date."

FOP Labeling & New 'Healthy' Claims Are Changing Packaging

A focus on public health and the prevention of chronic disease drives the second major shift. The result is a fundamental change to not just what can go in a product, but what must be communicated on the product. 

Read More: The FDA Updated the Definition of 'Healthy' — Here's What it Means for Your Food Labels

Front-of-Pack (FOP) Labeling is on the Horizon  

While many countries, including Mexico and Canada, already have mandatory FOP labeling, the U.S. is now moving firmly in that direction. The FDA has proposed a standardized "nutrition info box" for the front of packages, designed to give consumers at-a-glance information. 

The proposed FOP label would: 

• Complement the existing Nutrition Facts label. 
• Feature simplified information for saturated fat, sodium, and added sugars.
• Include level indicators to show whether a nutrient is "low, medium, or high". 

Raising the Bar on "Healthy" and Defining "Ultra-Processed"  

Beyond FOP, regulators are redefining foundational nutrition terms. In December 2024, the FDA announced a new, more stringent definition for the "healthy" claim on food packages. The updated rule requires a product to not only stay below set limits for nutrients like saturated fat, sodium, and added sugars, but also to contain a meaningful amount of food from a specific food group, like fruits or vegetables. 

Digital Download: 2024 Consumer Sentiment Report 

Looking ahead, the next major frontier is the regulation of "ultra-processed foods" (UPFs). The FDA commissioner has confirmed the agency is actively working on an official definition for these foods. Murphy anticipates this definition will be multifaceted. "We may expect that definition to include nutrients to limit such as added sugars," she stated, adding that the agency would also "consider synthetic dyes, emulsifiers, and preservatives when crafting that definition". 

A Proactive Strategy and Digitization Will Help Companies Keep Up 

This regulatory environment has a profound impact on operations. A single ingredient restriction can trigger a massive internal workload, affecting product developers, nutrition staff, QA teams, supply chain managers, and marketers simultaneously. It forces companies to revisit everything from allergen statements to nutrition panels, often across hundreds of SKUs. 

Watch Now: Introducing Genesis Foods — From Product Formulation to Compliant Labeling

The biggest challenge, Murphy notes, is strategizing in a world of overlapping initiatives. "If you have overlapping initiatives all at once, a producer may feel they're making packaging updates constantly". The most effective way to manage this complexity effectively is to move from reactive scrambling to a proactive, digitized strategy, she advises. 

"I think what's key is digitizing information. Having it all in one place is crucial to be able to shift as needed. Companies should set up clear protocols from the beginning to the end of a life cycle so that they can attest that their information is sound and accessible at a moment's notice." 

A robust, centralized platform ensures that when teams change or people leave the company, the data remains consistent and trustworthy, ready for an audit or a recall at a moment's notice. 

Changing Food Regulations: Frequently Asked Questions (FAQ) 

What is the California Food Safety Act? The California Food Safety Act is a state law that, effective January 1, 2027, will ban the use of four specific food additives in products sold in the state: brominated vegetable oil, potassium bromates, propylparaben, and Red Dye No. 3. 

What is the FDA's proposed Front-of-Pack (FOP) label? It's a proposed "nutrition info box" for the front of food packages. It is designed to complement the existing Nutrition Facts label by providing simplified information on saturated fat, sodium, and added sugars, along with indicators for whether the levels are "low, medium, or high". 

Is the FDA planning to regulate ultra-processed foods (UPFs)? Yes, the current FDA commissioner has stated that the agency is working on an official definition for ultra-processed foods. This definition is expected to consider not just nutrients like added sugars but also ingredients such as synthetic dyes, emulsifiers, and preservatives. 

What is the new definition of a "healthy" food claim? The new definition, announced in December 2024, is more stringent. To qualify, a food must now meet two criteria: 1) It must contain a meaningful amount from a specific food group (like fruits or vegetables), and 2) it must stay below specific limits for saturated fat, sodium, and added sugars. 

Bonus Takeaway: Trustwell Has Tools for The Great Reformulation 

Navigating new food regulations is a lot easier if you have the right tools and technology. Our solutions are built to turn these regulatory challenges into a competitive advantage. 

• Genesis Foods: Our next-generation formulation software allows you to reformulate products while immediately seeing the impact on the formulation. You can increase your speed to market without sacrificing the safety and transparency your customers expect. 

• AskReg: We've implemented an AI-powered model directly within our platform that acts as your regulatory expert. Murphy explains, "It will let a user know if an ingredient that they have entered has been potentially banned or restricted...having that at your fingertips while you're working will help save time and allow the user to be productive in real time". 

• Trustwell Connect: Our platform digitizes the entire supply chain, allowing you to connect formulation, compliance, and data through all of your processes for unmatched traceability and control. 

Rapid regulatory change doesn't need to slow you down. Get in touch today to see how Trustwell can help you master the great reformulation.