FDA Proposes to Make GRAS Notifications Mandatory
For decades, companies have been able to “self-affirm” that a substance is generally recognized as safe (GRAS) without notifying FDA, allowing certain substances to enter the food supply without direct agency review. That framework could soon change. In a proposed rule published August 11, 2026, FDA would require any person who introduces a substance into […]
Federal Legislation Would Deem 15 Chemicals Unsafe in Food Packaging
On June 9, 2026, lawmakers introduced the No Toxic Chemicals in Food Packaging Act of 2026, which would ban 15 chemicals or chemical classes—including PFAS, ortho-phthalates, and bisphenol A—from food-contact use. H.R.9231 was introduced by Rep. Jan Schakowsky (D-IL) and Rep. Rosa DeLauro (D-CT) and has been referred to the House Committee on Energy and […]
EPA Avoids Court Order on Organophosphates, but Timeline Concerns Remain
The Ninth Circuit has declined to force EPA to act on a petition brought by nonprofits targeting organophosphate pesticides, calling the request “premature” despite noting concerns with the agency’s response timeline for certain pesticides. The 2021 petition, brought by environmental and farmworker groups, asks EPA to revoke Federal Food, Drug, and Cosmetic Act (FFDCA) food […]
GRAS Reform Update: Where Do Things Stand?
For decades, food manufacturers have relied on a regulatory pathway known as Generally Recognized as Safe—or GRAS—to introduce substances into the food supply without formal FDA approval. Under this framework, a substance may bypass the agency’s premarket review process if qualified experts generally recognize it as safe for its intended use. That practice is now […]
Tennessee Bill Targets “Forever Chemicals” in Food
Tennessee lawmakers have introduced legislation that would prohibit the sale of food containing PFAS beginning July 1, 2026, “unless the food is labeled as containing forever chemicals and discloses the known or possible health effects of the chemical.” The legislation defines a “forever chemical” as a PFAS, described as a “group of man-made synthetic chemicals, […]
FDA Withdraws Asbestos Testing Proposal for Talc Cosmetics
On November 28, 2025, in response to adverse comments, FDA published a notice announcing its withdrawal a December 2024 proposed rule that would have required manufacturers of talc-containing cosmetic products to test for asbestos. The rulemaking is required by section 3505 of the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), which directs FDA to […]
FDA Defends Phthalate Food Additive Authorizations in Legal Challenge
FDA acted reasonably when it denied a petition seeking to remove authorization for five phthalate chemicals used as food additives, the FDA told the D.C. Circuit on August 13, 2025. The case, Alaska Community Action on Toxics v. FDA, No. 24-1382, marks the latest dispute over the safety of chemicals long used in food packaging […]
Are You Ready for Mandatory GRAS Notifications?
The second Trump administration’s first Unified Regulatory Agenda of Federal Regulatory and Deregulatory Actions, published September 4, 2025, indicates that FDA is close to initiating a rulemaking to overhaul the generally recognized as safe (GRAS) regulations—a change that could significantly raise regulatory expectations for food manufacturers and ingredient suppliers. What Does the Unified Agenda Say? […]
EPA Releases Strategic Plan for Endocrine Disruptor Screening Program
EPA has released a notice requesting comment on its strategic plan to meet its obligations under the Federal Food, Drug, and Cosmetic Act (FFDCA) to screen for and protect against endocrine-disrupting effects in humans. Endocrine disruptors are chemicals that mimic, block, or disrupt the normal function of endocrine system hormones and can negatively impact biological […]
Eight Circuit Vacates Chlorpyrifos Ban
EPA’s ban on the pesticide chlorpyrifos was arbitrary and capricious because the Agency failed to adequately consider other options, the Eighth Circuit Court of Appeals ruled on November 2, 2023, in the case Red River Valley Sugarbeet Growers Ass’n v. Regan. EPA’s 2021 revocation of all chlorpyrifos tolerances was the result of a Ninth Circuit […]