Artificial Food Coloring: The FDA Review That's Finally Happening

The FDA regulates 78% of the U.S. food supply. It decides which additives are permitted, which labeling claims are allowed, and which ingredients get reviewed or pulled. Changes at the FDA — real ones, not just press release ones — eventually show up in what's on grocery store shelves.

With the current administration prioritizing food safety reform under the MAHA framework, the FDA's food division is under more scrutiny than it has been in decades. Some of that scrutiny is warranted. Some of the proposed changes are straightforward policy improvements that have been advocated for by researchers and consumer groups for years. Others are more contested.

Here's what's actually happening — without the hype in either direction.

How FDA Food Policy Works (What Critics Often Miss)

The FDA doesn't wake up one morning and ban an ingredient. The regulatory process is slow, legally constrained, and deliberately deliberate. Understanding the machinery explains why change takes years even when intentions are clear.

The Rulemaking Process

Any significant food policy change requires a formal rulemaking process:

1. Proposed Rule — The FDA publishes a proposed rule in the Federal Register with supporting scientific basis
2. Public Comment Period — Typically 60–90 days for public and industry comment
3. Response to Comments — FDA must respond substantively to significant comments received
4. Final Rule — Published with effective date, often 1–2 years after the proposed rule
5. Legal Challenges — Affected industries routinely challenge rules in federal court

This process for a single ingredient change can take 3–7 years. For systemic reform of processes like GRAS, the timeline extends further.

What the FDA Food Division Actually Covers

The FDA's Center for Food Safety and Applied Nutrition (CFSAN) oversees:

• Food additives and color additives — Premarket approval required
• GRAS substances — Self-certified as safe by manufacturers, with FDA notification (not mandatory approval)
• Dietary supplements — Regulated differently from food; largely post-market system
• Food labeling — What can and can't be claimed on packaging
• Contaminant limits — Lead, arsenic, pesticide residues
• Food facility inspections — Manufacturing safety standards

These are distinct regulatory programs with different legal authority structures. "FDA food policy changes" is not one thing — it's dozens of different programs, each with its own change process.

📖 Related: For the full policy landscape, read How Government Health Policy Works: A Citizen's Guide, Health Sovereignty: Your Right to Make Your Own Health Decisions, and Organ Meats: The Ultimate Beginner's Guide to Nose-to-Tail Eating.

What's Actually Changing: The Real Policy Shifts

The GRAS System: Long-Overdue Reform?

The GRAS designation was created in 1958 to exempt substances "generally recognized as safe" from the full food additive approval process. The idea was that things like table salt and vinegar didn't need elaborate pre-market review.

The problem: the GRAS system has evolved into something its architects didn't design it for. Food companies can now self-certify novel ingredients as GRAS without ever notifying the FDA — a practice the Government Accountability Office criticized in 2010, 2015, and again in subsequent reviews.

The current administration has signaled interest in GRAS reform. What that looks like in practice is still developing, but several proposals have circulated:

• Making FDA notification mandatory (rather than voluntary) for GRAS determinations
• Requiring independent third-party safety reviews for novel ingredients
• Establishing time-limited GRAS approvals that require periodic re-review

These are not radical proposals. Food safety advocates across the political spectrum have supported some version of GRAS reform for 15+ years. Whether they get implemented through administrative action or require Congressional legislation is the key question.

Food Dye Review

The FDA has already taken action on Red Dye No. 3 (erythrosine), which was banned from cosmetics in 1990 due to cancer risk but remained permitted in food — a long-running regulatory inconsistency. In early 2025, the FDA moved to revoke its approval in food.

Additional synthetic dyes are under heightened review. Several have been banned in the European Union for years, creating the situation where American food products sold abroad are reformulated with natural colorings while domestic versions retain synthetic dyes.

This is a concrete, measurable policy change. It's also a change that was already in process before the current administration — illustrating that some of what's being claimed as MAHA policy victories were already in motion through the regular regulatory process.

Brominated Vegetable Oil (BVO)

The FDA finalized the revocation of BVO's authorization for use in food in July 2024. BVO had been used as an emulsifier in citrus-flavored drinks for decades despite a provisional authorization that was never converted to permanent. This is another example of a long-standing regulatory anomaly being resolved.

Seed Oils: Advocacy vs. Regulation

The MAHA movement's concerns about industrial seed oils (soybean, canola, corn, cottonseed) are among its most prominent food positions. It's worth being precise about what FDA can and cannot do here.

Seed oils currently on the GRAS list cannot simply be removed by administrative fiat. The FDA would need to demonstrate that new scientific evidence shows they are no longer safe — a high evidentiary bar that current consensus research does not support, regardless of what individual advocates argue.

What's more plausible: changes in how these oils are featured in dietary guidance documents (a USDA/HHS function, not FDA), increased scrutiny of specific processing methods, or labeling requirement changes that make seed oil content more visible to consumers.

What's Not Changing: Realistic Expectations

The Food Supply Won't Be Upended Overnight

Despite the dramatic framing in some media coverage (both pro and con), the FDA food regulatory system has enormous inertia. Legal challenges, statutory constraints, and the sheer complexity of the food supply mean radical rapid change is essentially impossible.

Companies that have invested decades in manufacturing processes built around specific ingredients don't quietly accept regulatory changes. They sue. And they often win, or at minimum delay implementation for years.

Industry Reformulation vs. Regulatory Bans

An underappreciated dynamic: some of the most significant changes to the American food supply come through market pressure and voluntary reformulation, not regulation. When PepsiCo and Kraft voluntarily removed BVO from some products years before the FDA ban, that was market-driven change.

The current administration's public pressure on food companies — through speeches, social media, and regulatory signals — may drive more voluntary reformulation than any single regulatory action. This is neither good nor bad; it's how the system often works.

Dietary Supplements Remain Lightly Regulated

One area where the administration's food safety rhetoric doesn't match the regulatory reality: dietary supplements are regulated under a completely different framework (DSHEA, from 1994) that makes them significantly harder to regulate than food additives. Claims of regulatory attention to supplement safety rarely produce the changes advocates want, given the statutory constraints.

What This Means for What You Actually Eat

For people already making conscious food choices — prioritizing whole foods, reading ingredient labels, avoiding ultra-processed products — the policy changes described above represent a gradual alignment between regulatory reality and the choices you're already making.

Practically:

• Reformulations are coming to some products. Companies are watching regulatory signals and reformulating proactively
• Labeling changes may make it easier to identify certain ingredients
• Some specific additives will face faster review timelines than they would have under previous administrations
• The fundamental structure of food regulation isn't being dismantled — it's being adjusted at the margins

The deepest change may be cultural rather than regulatory: FDA leadership publicly skeptical of certain food ingredients changes what gets studied, what gets flagged in inspections, and what industry considers acceptable risk.

📖 Related: What to eat instead is covered in Health Sovereignty: Your Right to Make Your Own Health Decisions and Organ Meats: The Ultimate Beginner's Guide to Nose-to-Tail Eating.

Frequently Asked Questions

Q: Is the FDA banning seed oils? A: No. Seed oils are not under formal FDA review for revocation. What's changed is the political environment around these ingredients, which may drive more research and voluntary industry reformulation. Regulatory bans would require years of formal process and strong scientific evidence currently not present in the mainstream literature.

Q: What food additives is FDA actually reviewing right now? A: Active areas of review include synthetic food dyes (beyond Red Dye No. 3), certain preservatives, and aspects of the GRAS notification system. The FDA publishes active regulatory actions at fda.gov/food — this is the most reliable source.

Q: Will food get more expensive if FDA tightens regulations? A: Regulatory compliance costs typically do get passed to consumers to some degree. However, the timeline for significant regulatory changes is long enough that price impacts would be gradual. Voluntary reformulation by major manufacturers (which is already happening) may have more near-term effect on food composition than regulatory mandates.

Q: How does the FDA decide what ingredients are safe? A: For food additives requiring approval, FDA uses a "reasonable certainty of no harm" standard based on available scientific evidence. For GRAS substances, the standard is the same but is applied by the manufacturer rather than FDA. This distinction is at the heart of current reform debates.

Q: Can I comment on FDA food policy changes? A: Yes. All proposed rules are published in the Federal Register with public comment periods. Regulations.gov allows you to find active dockets and submit comments. Individual comments from citizens are counted and must be substantively addressed in final rules.

The Bottom Line

The FDA's food policy is changing, but slowly and within well-established legal constraints. Specific additive reviews, GRAS system reform pressure, and a changed enforcement priority environment are real. Wholesale bans of major ingredient categories are not happening in the near term.

The most important changes may be the ones happening voluntarily — food companies reformulating to get ahead of regulatory uncertainty and public opinion. Watch what companies do with their ingredient lists over the next 12–24 months as much as what the FDA formally announces.

For citizens who want to engage: regulations.gov is your venue. Use it.

→ [Which food ingredients are under review? Our MAHA breakdown → /fda-food-ingredients-maha] → [The full HHS agenda explained → /hhs-rfk-jr-citizen-guide]

This article is citizen journalism and policy commentary. It does not constitute official regulatory guidance. For current FDA actions, visit fda.gov/food.