Labeling Regulations Uncovered: A Look at the Latest Updates

Regulatory agencies such as the Food & Drug Administration (FDA) and Alcohol and Tobacco Tax and Trade Bureau (TTB) have recently proposed and/or finalized several regulations pertaining to the labeling of food & beverages – many with the intention of improving overall health.

With recent changes in federal administration, there is more uncertainty about the state of the US food supply and priority of impending new regulations, many of which could have significant financial and operational impact.

Outlined below are some of the most recent proposed/finalized regulation updates that manufacturers should be aware of to best prepare for significant change when necessary. Regulation topics of relevance include:

• The updated definition of “Healthy” for use as a claim
• “At a glance” Front-of-Packaging (FOP) nutrition labeling
• Efforts to phase out artificial petroleum-based colorants
• Proposed “Alcohol Facts” labels for TTB-regulated beverages.

Below is a detailed overview of each pending regulation change, outlining key updates and their implications.

Updated Definition of “Healthy” Claim

The FDA has finalized an updated definition of the nutrient content claim "healthy" to better reflect current nutrition science and dietary guidelines which will impact how manufacturers can market their products and the criteria to use this claim on labels. The updated definition is based on two components:

1. Food Group Equivalents (FGEs)

A product must meet a certain threshold, or thresholds of the food groups recommended by the current Dietary Guidelines for Americans (DGAs): Fruits, Vegetables, Grains, Dairy, Protein, & Certain Oils

• Whole/sliced fruits, vegetables, unsalted nuts, brown rice, and frozen mixed vegetables automatically qualify (no added ingredients except water)
• Individual Ingredients
  

  Grains	¾ ounce equivalent (whole grain)
  Dairy	2/3 cup equivalent
  Vegetables	½ cup equivalent
  Fruits	½ cup equivalent
  Game Meat	1 ½ ounce equivalent
  Seafood	1 ounce equivalent
  Eggs	1 ounce equivalent
  Beans, Peas, Lentils	1 ounce equivalent
  Nuts, Seeds, & Soy	1 ounce equivalent

• Combination Foods
  

  Mixed Products	at least 1 FGE with no less than ¼ FGE from 2 FGEs
  Main Dishes	at least 2 FGEs with no less than ½ FGE from at least 2 FGEs
  Meals	at least 3 FGEs with no less than ½ FGE from at least 3 FGEs

2. Nutrients to Limit (NTLs)

Product must fall below certain thresholds for saturated fat, sodium, and added sugars, expressed as a percentage of the Daily Value (DV).

• Whole/sliced fruits, vegetables, unsalted nuts, brown rice, and frozen mixed vegetables automatically qualify (no added ingredients except water)
• Individual Ingredients
  

  	Saturated Fat	Sodium	Added Sugar
  Grains	5% DV	10% DV	10% DV
  Dairy	10% DV	10% DV	5% DV
  Vegetables	5% DV	10% DV	2% DV
  Fruits	5% DV	10% DV	2% DV
  Game Meat	10% DV	10% DV	2% DV
  Seafood	5% DV*	10% DV	2% DV
  Eggs	10% DV	10% DV	2% DV
  Beans, Peas, Lentils	5% DV	10% DV	2% DV
  Nuts, Seeds, & Soy	5% DV*	10% DV	2% DV
  Oil-based Dressing	20% of total fat	10% DV	2% DV
  Oil-based Spread	20% of total fat	10% DV	0% DV
  100% Oil	20% of total fat	0% DV	0% DV

  *excluding inherent SFA
  
  
• Combination Foods
  

  	Saturated Fat	Sodium	Added Sugar
  Mixed Products	10% DV (2 g)	15% DV (345 mg)	10% DV (5 g)
  Main Dishes	15% DV (3 g)	20% DV (460 mg)	15% DV (7.5g)
  Meals	20% DV (4 g)	30% DV (690 mg)	20% DV (10 g)

Front-of-Package (FOP) Labeling

The proposed regulations would require easily noticeable & obvious nutrition information separate from the Nutrition Facts Panel with the intent to draw immediate attention to the consumer’s dietary choices.

These requirements are also meant to complement FDA’s 2016 Nutrition Facts Panel regulation updates, as well as updated definition for “Healthy” and sodium reduction efforts, previously described. FOP verbiage would include “Low”, “Med”, and “High” to flag nutrient content with respect to %Daily Value:

• ≤ 5% = Low
• 6-19% = Med
• ≥ 20% = High

Required	Required, with optional Calories

Required for Intermediate Packages	Dual formats

Artificial Dyes & Colors

Most recently, the FDA proposed a robust phase-out of many petroleum-based synthetic dyes by the end of 2026. The proposal stems from concerns surrounding the impact of artificial dyes on health issues such as diabetes, obesity, and behavioral issues – particularly in children. The FDA is targeting the following:

• Citrus Red 2 and Orange B (within the coming months)
• FD&C’s Green 3, Red 40, Yellow 5, Yellow 6, Blue 1, and Blue 2 (by the end of 2026)
• FD&C’s Red 3 (recently banned in 2025 for new foods, but FDA is requesting cooperation to remove sooner than deadline of 2027 for food)

Food manufacturers will need to change the recipes for numerous items – brightly colored sweets, beverages, breakfast cereals, and packaged meals, etc. – to swap out the synthetic coloring agents that are under scrutiny for naturally derived alternatives. To help with this transition, the FDA has approved the following natural alternatives for use:

• Calcium phosphate
• Galdieria extract blue
• Butterfly pea flower extract

The FDA is actively assessing other natural color alternatives, including Gardenia blue, for potential use in food and beverages.

Other world regions, such as the European Union, have already taken steps to reduce the use of artificial food colorings in food. For example, the use of mandatory warning labels has prompted numerous companies to opt for natural substitutes such as beet juice, turmeric, and safflower extracts. Furthermore, California has acted within its own borders by limiting the use of synthetic dyes in school lunches and mandating warning labels on foods containing them.

TTB’s Alcohol Facts Label

The Alcohol and Tobacco Tax and Trade Bureau (TTB) has put forward a suggestion for a mandatory "Alcohol Facts" label. This label would detail calorie, carbohydrate, fat, and protein content, in addition to alcohol by volume and serving size. This proposal marks a substantial step forward in making nutrition information available for alcoholic drinks, which have traditionally been subject to different labeling rules compared to food items.

Proposed components of the Alcohol Facts label include the following:

Along with the Alcohol Facts label, the TTB has also proposed requiring the declaration of major food allergens used in producing alcoholic beverages, like FDA requirements. Those allergens include:

• Milk
• Eggs
• Soybeans
• Fish
• Crustaceans
• Wheat
• Tree Nuts
• Peanuts
• Sesame

How can Eurofins help?

To navigate the complexities of the global landscape, staying ahead of regulatory changes is paramount.
Eurofins understands the dynamic nature of the food & beverage industry and remains steadfast in its commitment to staying ahead of regulatory changes. This proactive approach ensures that our clients have seamless access to crucial resources.

Leveraging our extensive and multi-faceted network of expert laboratories strategically positioned across the world, Eurofins is a convenient and comprehensive one-stop shop for all testing needs, regardless of location.

We pride ourselves on offering a comprehensive repertoire of services, and our commitment to continuous growth ensures our profile consistently evolves to not only meet but also anticipate the ever-changing demands of regulatory requirements on a global scale.

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