CHOICES
A publication of AAEA
The US is in an era of unprecedented changes in policies affecting production and consumption of food products. Although some changes had been in process under the prior federal government administration, the Make America Healthy Again (MAHA) initiative is driving significant additional changes. The MAHA initiative released an assessment report in May 2025, followed by a strategy report in September 2025. The strategy report included numerous strategies focused on the food system, such as simplifying the Dietary Guidelines for Americans (DGAs), reforming the new ingredient notification program called Generally Recognized as Safe (GRAS), and defining ultra-processed foods (UPFs) to support future research and policy (MAHA, 2025b). The new DGAs were released in January 2026, following a different process than had been used in the past, and changed some long-standing recommendations, particularly regarding consumption of protein and animal fats (DHHS and USDA, 2026a).
Some changes will benefit consumers if the food supply becomes healthier and more information is available for them to make healthy choices in grocery stores and restaurants. However, some efforts appear to be based on misleading information, which could result in less healthy food choices and potentially higher food costs for consumers. Examples of misleading information are the focus on removing artificial food dyes from foods that would not otherwise be considered healthy (Dunford et al., 2025), encouraging consumption of animal fats such as beef tallow and butter in place of seed oils such as canola or soybean oil (Corliss, 2025), and encouraging consumption of higher amounts of protein, particularly from animal sources, than is recommended based on nutrition science (Liebman, 2025).
This article highlights the following recent federal policy changes that could substantially affect the food system:
The focus is on how these policies will affect the food supply through changes in product offerings, either through introduction of new products or reformulation and relabeling of existing products. Understanding the supply-side effects of policies is important because product reformulation and product portfolio changes have been shown to reinforce public health goals of food policies worldwide (Salgado et al., 2025).
The US has experienced high rates of food price inflation in recent years, initially due to the COVID-19 pandemic but subsequently due to the effects of the highly pathogenic avian influenza outbreak on egg and poultry prices, high energy costs resulting from the Russia–Ukraine war, and other economy-wide inflationary factors such as supply-chain issues (ERS, 2026). After several years of inflation that was higher than the historical average, food prices are expected to increase 2.9% overall in 2026 (ERS, 2026). Changes in food policy that require or encourage food manufacturers to reformulate and relabel foods could put further pressure on food prices.
Although this article focuses on federal policies, state governments are also issuing regulations, some of which were initiated prior to the MAHA initiative. In some cases, these regulations are inconsistent with federal government policies. For example, some states have banned synthetic food dyes or other food additives in either all retail foods or in foods served in public schools (Baker-White, 2025; EWG, 2026). This patchwork of regulations can contribute to increased costs of production because most food manufacturers produce foods that are sold nationally or across multiple states (Kalaitzandonakes and Ridley, 2025; van Laack and Snow, 2025). Food manufacturers have urged Congress to pass legislation that would preempt state regulations for food dyes and additives (Erdenesanaa, 2026) because it would be difficult and costly for manufacturers to produce different versions of products for different markets.
Since 1994, food manufacturers have been able to use a “healthy” claim on foods that meet criteria set by FDA (2025e). The original definition included limits on total fat, saturated fat, cholesterol, and sodium along with requirements for providing at least 10% of the daily value for vitamin A, vitamin C, calcium, iron, protein, and fiber. Using 2023 data, FDA estimated that about 10% of the products on the market qualified to use a “healthy” claim, but that only about half did so (FDA OC, 2024). In response to a December 2015 citizen’s petition and updates to FDA’s strategic plan for nutrition labeling regulations, FDA initiated a process to update the criteria that food products must meet to be able to use the “healthy” claim. FDA subsequently issued a final rule in December 2024. Instead of limits on total fat, saturated fat, cholesterol, and sodium, limits were set for added sugars, saturated fat, and sodium. In addition, instead of requirements for meeting thresholds for specific nutrients, foods must contain a specific amount from one of the food groups recommended in the 2020–2025 DGAs (fruit, vegetables, grains, fat-free and low-fat dairy, and protein foods) (FDA, 2025e). The compliance date for the final rule is February 25, 2028. Currently, FDA is reassessing whether changes are necessary to align with the new DGAs and might develop a symbol for the “healthy” claim (FDA, 2026).
In the final economic analysis for the “healthy” claim rule, FDA estimated the number of products that might be relabeled or reformulated in response to the rule (FDA OC, 2024). Using the label is voluntary, but food manufacturers would need to either relabel or reformulate products that no longer meet the definition. In addition, food manufacturers could decide to reformulate products that do not currently meet the definition to allow them to begin using the label. Of the estimated 268,419 products on the market, FDA estimated that 11,166 (4.2%) would have to remove the claim or reformulate, and 10,162 (3.8%) would add the claim. Of those 11,166 products, FDA estimated that 363 unique formulas representing multiple package sizes would be reformulated. To estimate benefits associated with the regulation, FDA calculated the value of the reduction in chronic, diet-related diseases assuming about 2% of the US population would use the healthy claim in a meaningful way.
Front-of-package (FOP) nutrition labels are mandated in several countries, including Mexico and Canada, but were only recently proposed in the US in January 2025. Some US food products already include voluntary FOP labels under industry-led programs such as Facts Up Front and the American Heart Association’s Heart-Check program (Pomeranz et al., 2019). Since 2007, FDA has conducted research on a potential FOP label including experimental studies of possible label designs and literature reviews on experimental and real-world studies of FOP labels (FDA, 2025a). Information provided in a citizen petition submitted in August 2022 also informed the design of a proposed FOP label. Under the proposed rule, all food labels must display a Nutrition Info box (see Figure 1) showing the percentage daily value and levels of saturated fat, sodium, and added sugar per serving (FDA, 2025a). A final rule has not yet been published, and thus a compliance date has not yet been set.
In the draft economic analysis of the FOP rule, FDA followed a similar process as for the “healthy” claim except that all packaged foods in the US would be required to be relabeled (FDA OC, 2025). Reformulation could also be a voluntary response if manufacturers want to ensure that foods appear healthy based on the nutrients shown on the FOP label. Of FDA’s estimate of 322,326 products on the market, all would need to be relabeled, although some manufacturers might be able to coordinate the label update with a routine update. To estimate the number of reformulated products, FDA identified those that were slightly above the thresholds to be labeled as low or medium and assumed they would be reformulated, resulting in an estimated 1,521 (0.5%) products. The benefits of the rule were described qualitatively in terms of nutritional improvements because the FOP label would allow consumers to quickly and easily identify healthy foods and result in improvements in the healthfulness of the food supply from voluntary reformulation.
A substantial early emphasis of the MAHA initiative has been on encouraging food manufacturers to remove synthetic food dyes and other additives from foods. So far, most of the attention has focused on synthetic food dyes. For the most part, MAHA’s interest in removing other additives from the food supply is taking place through changes in the GRAS process and recommendations to limit consumption of UPFs (discussed below).
In April 2025, FDA issued a press release regarding the phaseout of synthetic dyes from the US food supply (FDA, 2025b). Despite some media portrayals, FDA has not issued regulations requiring the removal of synthetic food dyes or the substitution of natural food dyes in place of synthetic versions under this administration. Under the prior administration, the use of FD&C red dye no. 3 was banned, and food manufacturers must stop using it by January 14, 2027. Many food manufacturers have announced their decisions to remove voluntarily other types of synthetic food dyes from at least some of their products. FDA maintains a tracker of these companies on its website (FDA, 2025c). FDA is encouraging the development of new natural food dyes and will accelerate the review and approval of new submissions (FDA, 2026). Some states have taken a stronger stance against synthetic food dyes, particularly in foods served in public schools, and have issued bans on the sale of foods containing certain dyes or will require warning labels (Baker-White, 2025).
To remove synthetic food dyes, food manufacturers will need to identify suppliers for natural food dyes, test use of the new dyes in their production processes, conduct market testing to ensure consumer acceptance, and relabel to update ingredient lists. The ongoing costs of natural dyes may be substantially higher than synthetic versions (Aleccia, 2025). Because there is some risk related to consumer response to the changes, some food manufacturers are creating new versions of products while continuing to sell existing versions (for example, Doritos and Cheetos [Lavietes, 2025]). Some synthetic food dyes have been shown to be associated with neurobehavioral problems in some children who could therefore benefit from their removal (Dunford et al., 2025). However, many foods that contain artificial dyes are also high in added sugars, so substituting natural dyes for synthetic dyes will not make those foods healthier.
For an ingredient to be used in foods, it must either be GRAS or approved as a food additive through a lengthy premarket review process. In 1961, FDA created an initial list of foods that were considered GRAS, but companies could submit requests for FDA to affirm the GRAS status of additional ingredients (FDA, 2006). In 2016, FDA formalized a GRAS notification process for companies to notify FDA that they have conducted their own review of an ingredient, and FDA could approve it or respond that the information provided was insufficient to determine GRAS status (FDA, 2016). This process is known as the “GRAS loophole” because companies could introduce new ingredients to the food supply without undergoing FDA’s safety review. Also, many companies have introduced new ingredients without ever notifying FDA of their use (EWG, 2025). The MAHA strategy report said that FDA would close the GRAS loophole by implementing a mandatory notification system and that some existing substances in foods might need to be removed (MAHA, 2025b). FDA announced in October 2025 that it is undertaking rulemaking regarding the GRAS process (DHHS, 2025) and will publish a proposed rule in 2026 (FDA, 2026).
A change in the GRAS process and the inventory of GRAS substances could result in substantial changes to products on the market. According to Pomeranz, Leib, and Mozaffarian (2024), there are likely numerous ingredients in the food supply that have not been reviewed by FDA and are of unknown safety to the public. FDA has revoked the GRAS status of food substances in the past, as it did for partially hydrogenated oils in 2018 because of concerns about consumption of trans fatty acids (Pomeranz, Leib, and Mozaffarian, 2024). Once safety reviews are completed, some food manufacturers might need to stop production of foods containing certain ingredients or reformulate them to use alternative ingredients.
An estimated 70% of the US food supply comprises UPFs, and concerns about consuming UPFs is increasing (Vadiveloo et al., 2025). Studies have linked consumption of UPFs with increased risk of heart disease, type 2 diabetes, and obesity (Vadiveloo at al., 2025). Although UPFs are often thought to be synonymous with “junk food,” not all UPFs are unhealthy, such as some whole grain breads and yogurts. In many studies, the Nova classification system, introduced in the seminal article by Montiero et al. (2011), has been used to identify foods that are considered UPFs based on the amount of processing and use of additives. Other definitions of UPFs have been developed, but there is not yet a federal definition. In July 2025, FDA and USDA jointly published a request for information (RFI) to gather information from the public for developing a definition for use in research and policy (FDA, 2025d). The RFI requested information on the attributes of foods that could be used to define UPFs, such as types of ingredients, types of processing, and nutritional content (FDA and USDA, 2025). FDA is currently reviewing the comments and has not yet developed a plan for addressing UPFs (FDA, 2026).
Despite the attention on UPFs, it is not yet known how the federal government might issue guidance or regulations related to the production and marketing of UPFs. A federal definition could help guide new analyses to determine what portion of the food supply is considered ultra-processed and to analyze relationships between UPF consumption and health outcomes. The federal government could require some type of label, like the FOP label, indicating whether a food is ultra-processed, or revise the FOP design to include a UPF indicator. This type of requirement could cause food manufacturers to voluntarily reformulate existing foods toensure they are not subject to a UPF labeling requirement or introduce alternative versions of some foods.
Every 5 years, the Department of Health and Human Services (DHHS) and USDA convene a scientific advisory committee to review the scientific evidence on nutrition and public health and provide recommendations to the federal government (DGAC, 2024). DHHS and USDA use the committee’s report to prepare the official DGAs and a graphic summary of the recommendations. The DGAs inform federal activities such as nutrition education materials and guidelines for federal nutrition programs like school meals, but they are used more broadly for nutrition programs across local and state governments and other organizations. With the change in administration, the DGA process diverged from past iterations in that a second advisory committee was convened to conduct additional scientific reviews because of concerns about too much focus on equity considerations and public policy preferences in the initial report (DHHS and USDA, 2026a). The final 2025–2030 guidelines report was released in January 2026 (DHHS and USDA, 2026b) and an accompanying website, realfood.gov, was launched. Shortly after the release of the DGAs, the president signed the Whole Milk for Healthy Kids Foods Act, which reinforces the DGA recommendation for children to consume full-fat dairy products and allows schools to offer whole milk (USDA, 2026).
With the DGAs release, the graphic summary of the guidelines changed from MyPlate to the New Pyramid (Figure 2). The New Pyramid shows a heavy emphasis on consumption of proteins and fats derived from animal sources. The new guidelines have been applauded for encouraging consumption of fruits, vegetables, whole foods, and water and maintaining limits on saturated fat and sodium (Lurie, 2026; Mozaffarian, 2026). For the first time, the guidelines discourage the consumption of highly processed foods (Mozaffarian, 2026), although the term UPF is not used. The guidelines have been criticized for encouraging more protein consumption (especially from animal sources), butter, beef tallow, and full-fat dairy (Lurie, 2026; Mozaffarian, 2026). It is too early to tell how the new DGAs will influence product portfolios of food manufacturers, but if guidelines for federal programs change, it could change the types of products they supply to those programs. It could also change demand for some types of products if consumers are exposed to nutrition education based on the new guidelines, thus encouraging food manufacturers to reformulate existing products or introduce and promote new products that align with the recommendations.
As described above, changes in food policy may cause food manufacturers to reformulate or relabel food products on a mandatory or voluntary basis. Food manufacturers incur costs for labor, utilities, and materials to undertake the series of activities required to implement the changes (Table 1). Costs of reformulation vary by the formulation (or recipe) complexity, the level and functionality of the affected ingredients, whether the food is shelf-stable or requires refrigeration or freezing, and company size (Muth et al., 2015b). Costs of relabeling vary by whether the change is a minor update to the information on the label or requires a complete redesign and the printing and packaging methods used (Muth et al, 2015a). When reformulating or relabeling, food manufacturers may also incur costs for analytical testing and market testing with consumers. Costs are higher when food manufacturers must make changes rapidly in response to a requirement. Generally, reformulation and relabeling are one-time costs. For some types of changes, food manufacturers might also incur higher costs of new ingredients purchased from the agricultural sector or ingredient manufacturers.
Examples of the level of costs for food policy changes that are in process are shown in FDA’s regulatory impact analyses. In its analysis of the final “healthy” label claim rule, FDA estimated about 0.8% of products sold in the US would be relabeled and 0.1% would be reformulated. The total industry costs were estimated to be $59 million for relabeling and $392 million for reformulation (FDA OC, 2024). In contrast, the proposed FOP label rule will affect all products sold in the US, and FDA estimated that 0.7% of products sold in the US would be reformulated. The total industry costs were estimated to be $1.3 billion for relabeling and $2.2 billion for reformulation (FDA OC, 2025).
The benefits of federal food policy include improvements in diet quality that lead to improved health and productivity and lower health care costs. A scoping review of the effectiveness of nutrition and environmental policies across the globe found that food labeling policies generally show a positive impact in terms of reducing intake of selected nutrients and influencing food reformulation (Burgaz et al., 2023). Specific to UPF food policies, a narrative review found that producer responses to food policy—such as reformulation, package size reductions, and changes in product portfolio—reduce consumption of health-harming nutrients (Salgado et al., 2025).
The value of health benefits associated with changes in federal policies can be substantial. For example, Huang et al. (2019) assessed the mandatory labeling of added sugars on packaged foods and beverages that went into effect in 2020 and calculated benefits associated with reductions in type 2 diabetes, coronary heart disease, and stroke from reduced sugar intake. Estimated healthcare savings were $31 billion, and societal savings from improvements in the quality of life were $61.9 billion over 20 years, assuming no industry reformulation. Values could be almost twice as large if some foods were also reformulated.
In FDA’s analysis of the “healthy” claim rule, which affects a small proportion of products on the market, the value of benefits resulting from reductions in chronic, diet-related diseases over a 20-year period was estimated to be $1.4 billion (FDA OC, 2024). FDA has not yet calculated benefits associated with the proposed FOP labeling requirement. However, the likely benefits could be similar to those in Huang et al. (2019) because the requirement will apply to all foods and beverages. Of the other policies described in this article, bans on synthetic food dyes, changes in the GRAS process, or a UPF labeling requirement could potentially lead to rulemaking requiring identifying and valuing benefits.
Many of the upcoming federal food policy changes will benefit public health, although potentially resulting in higher food prices for consumers. If food manufacturers are required to reformulate or relabel products, or choose to do so as a voluntary response, they will incur costs for new ingredients, undertaking reformulation, or designing new labels. Manufacturers might pass along the higher costs of these changes to consumers. In addition, with new information on product labels or nutritional recommendations, consumers might choose foods with desired attributes that have higher prices. If state governments move forward with regulations in the absence of federal regulation, production costs and thus food prices could increase if food manufacturers must produce different versions of products for different markets. Furthermore, to the extent that some changes might be made based on misleading information, costs might increase without providing a public health benefit. The changes described in this article are primarily under FDA’s purview. However, changes to SNAP (see Ver Ploeg, 2026) and other USDA programs will compound their effects and substantially alter the functioning of the US food system.
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