This Act mandates the FDA to systematically reassess the safety of at least ten existing food chemicals every three years, beginning in 2026, and take regulatory action if any substance is found to be unsafe.
Janice "Jan" Schakowsky
Representative
IL-9
The Food Chemical Reassessment Act of 2025 mandates that the FDA systematically review the safety of at least ten existing food ingredients every three years, starting in 2026. This process targets substances like certain food additives, colorings, and GRAS ingredients, prioritizing those with the greatest public health concern. If a reassessment determines a substance is unsafe, the FDA is required to take regulatory action, such as repealing approvals or revoking authorizations. The Act also establishes an advisory committee to guide the FDA on reassessment standards and methods.
FDA Mandated to Reassess Safety of 10 Common Food Chemicals, Including Red Dye 40 and BHA, Starting 2026
The Food Chemical Reassessment Act of 2025 is basically forcing the FDA to clean out the pantry and check the expiration dates on some of the oldest, most common ingredients in our food. Starting in 2026, the FDA’s Office of Food Chemical Safety has to systematically review the safety of at least 10 different food-related substances every three years. This isn’t a suggestion; it’s a mandatory, ongoing safety audit covering everything from color additives to ingredients that were previously approved under the “Generally Recognized As Safe” (GRAS) status, which sometimes means they haven’t been fully vetted by modern standards (SEC. 2).
The First 10 on the Chopping Block
This bill doesn’t make the FDA guess where to start; it names the first 10 substances that must be reviewed immediately. We’re talking about high-profile chemicals you see on ingredient labels every day, like Red dye 40, Yellow dye 5, and Yellow dye 6—the stuff that makes your kids’ snacks colorful. Also on the list are preservatives like BHA and BHT, which keep packaged foods from going stale, and Titanium dioxide, often used to whiten things like chewing gum and salad dressings. For the average person, this means the FDA will finally be using 2020s science to look at ingredients approved decades ago, potentially leading to big changes in the grocery aisle.
What Happens When the Safety Flag Rises?
If the FDA completes a reassessment and finds that a substance is no longer safe for public health, the bill requires immediate regulatory action. For food additives or color additives, the FDA must change or completely repeal the existing regulation (SEC. 2). If it’s a GRAS substance—a category often criticized because companies can self-certify—the FDA must post a determination online stating it’s unsafe. This is a crucial step for accountability, as it means the agency can’t just quietly shelve a negative finding. For food manufacturers, this process introduces a new layer of risk; if your product relies heavily on BHA for shelf life, you’ll need a contingency plan ready if the FDA pulls its approval.
The Advisory Committee and the Fine Print
To guide this massive undertaking, the Secretary must re-establish the Food Advisory Committee within 180 days of the law passing. This committee will be responsible for setting the standards and methods the FDA uses to conduct these reviews (SEC. 2). While this sounds technical, it’s where the rubber meets the road: the standards set here will determine how rigorous the reviews are. One thing to watch is the prioritization process. The FDA is supposed to prioritize reviews based on “public health needs,” which is a bit of a subjective term. This lack of specific, objective criteria means the agency has flexibility in deciding which chemicals get reviewed first after the initial 10, a point that could be influenced by public pressure or industry lobbying. However, the bill does make clear that this new, systematic review process doesn’t take away any of the FDA’s existing authority to enforce food safety laws otherwise.