The food and beverage industry is navigating a critical regulatory phase characterized by two powerful, converging forces: government-led safety and transparency mandates (like traceability and additive bans) and a consumer-led demand for wellness, clean labels, and sustainable nutrition. For formulators, this requires replacing legacy ingredients while documenting every step of the supply chain.
Here is a recap of the key regulatory shifts and wellness trends in 2025 and the critical compliance challenges to anticipate through 2026 and beyond.
I. Major Regulatory Changes in 2025: Additive Bans and Traceability Delays
The US saw aggressive state-level action on chemical ingredients, while the FDA provided relief on a massive new traceability rule.
A. US State-Led Food Additive Bans
State legislative momentum to ban common food additives accelerated dramatically, driven by public concern over chronic disease and ultra-processed diets.
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West Virginia Leads on Dyes: West Virginia enacted a sweeping ban on multiple food dyes and additives in 2025, a trend mirrored by over 20 other states. The law prohibits multiple dyes in school nutrition programs starting August 1, 2025, and designates foods containing additives like Red No. 40, Yellow No. 5, and Yellow No. 6 as adulterated starting January 1, 2028.
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Voluntary National Phase-Out: The FDA and HHS announced plans in May 2025 to work with the industry on a “voluntary” phase-out of six major synthetic dyes by the end of 2026, including Red 40 and Yellow 5, pushing manufacturers toward natural colors.
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Ultra-Processed Food (UPF) Scrutiny: San Francisco filed the nation’s first government lawsuit against food manufacturers over the health costs of ultra-processed foods (UPFs). This aligns with bills in states like California and Florida that aim to restrict UPFs in school meals.
B. Traceability and Safety Compliance
The regulatory burden for supply chain data collection increased, even with a major deadline extension.
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Food Traceability Rule Extension: The FDA announced its intention in March 2025 and proposed a rule in August 2025 to extend the compliance date for the Food Traceability Final Rule (FSMA 204). The deadline for entities that manufacture, process, pack, or hold foods on the Food Traceability List (FTL) moved from January 20, 2026, to July 20, 2028.
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Mandatory GRAS Reporting: The FDA introduced a proposed rule in 2025 that would require mandatory submission of Generally Recognized as Safe (GRAS) notices for all human and animal food substances claimed as GRAS, eliminating the previous self-determination process for many additives.
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II. Wellness Trends and Regulatory Focus for 2026 and Beyond
Future compliance will be dominated by the EU’s comprehensive sustainability framework and the accelerating consumer demand for functional, health-supporting foods.
A. EU “Farm to Fork” Strategy Finalization (2026-2027)
The European Green Deal’s Farm to Fork Strategy is the overarching regulatory framework driving systemic change in Europe.
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Deforestation-Free Compliance: The EU Deforestation Regulation (EUDR) applies from December 30, 2025, for large companies and June 30, 2026, for small companies, requiring rigorous due diligence to ensure supply chains are not linked to deforestation or forest degradation.
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Sustainable Food Systems Framework: A legislative framework is expected to be finalized, aiming to mainstream sustainability in all food policies and introduce new legal requirements for food products, including front-of-pack nutrition labeling and minimum criteria for sustainable public procurement.
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Packaging Mandates: New EU rules on packaging will require all packaging to be recyclable and plastic packaging to contain minimum amounts of recycled content, as well as set new limits on concentrations of substances of concern like PFAS.
B. The Rise of Functional Wellness
Formulation efforts will continue to concentrate on three major, high-growth wellness areas:
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Gut Health: Demand for fermented foods like kefir, kimchi, and kombucha remains strong, driven by their probiotic and prebiotic benefits. New innovation will focus on incorporating prebiotics and postbiotics into mainstream snacks and beverages.
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Accessible Nutrition & Satiety: With the rise of weight management medications (GLP-1 RAs), there is growing demand for nutrient-dense, satiety-boosting foods that support long-term health and prevent nutrient deficiencies, requiring increased protein and fiber formulation.
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Alcohol Alternatives: The push for updated cancer warning labels on alcoholic beverages following the 2025 Surgeon General’s Advisory is fueling massive growth in the no- and low-alcohol (NoLo) beverage market.
III. Actionable Steps
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Prioritize Additive Substitution: Immediately identify and substitute all synthetic dyes, especially Red 40, Yellow 5, and Yellow 6, and other at-risk additives like BVO, potassium bromate, and propylparaben, to preempt a complex, multi-state regulatory compliance nightmare.
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Establish Traceability Systems: Use the July 2028 deadline extension for the Food Traceability Rule to fully integrate electronic record-keeping systems that can track Critical Tracking Events (CTEs) and Key Data Elements (KDEs) for all foods on the FTL, ensuring coordination with supply chain partners.
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Future-Proof with Sustainability Data: Begin tracking and documenting supply chain origins, especially for commodities like soy and palm oil, to prepare for the EU Deforestation Regulation (EUDR) compliance starting in late 2025/mid-2026.
Sources
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Food and Beverage News and Trends – September 5, 2025 | DLA Piper
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The new rules of food and personal care products | Food Dive
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Food & Beverage Regulatory Update – June 2025 – Michael Best & Friedrich LLP
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Overview: EU Farm to Fork and Green Deal Initiatives – AGRINFO Platform
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EU actions against food waste – Language selection | Food Safety – European Union
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Insights on European Green Deal – Farm Management – University of Wisconsin–Madison
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Food Traceability Final Rule: Additional Guidance on the FDA’s New Regulations
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FDA Proposes Extension to Food Traceability Rule Compliance Date
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FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods
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FDA Issues Proposed Rule Extending Compliance Date for Food Traceability Rule
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FDA Intends to Extend Compliance Date for Food Traceability Rule
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HHS and FDA Announce Plans to Phase out Synthetic Food Dyes | Insights | Mayer Brown
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States Move to Regulate Artificial Food Dyes and Additives | MultiState
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Interactive map: Tracking state food chemical regulation in the U.S. – EWG
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San Francisco sues food giants over ultra-processed products
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Food Law in the States – 2025 Update – National Agricultural Law Center
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