Less federal oversight is a consistent theme across the U.S. government in 2026, and the Food and Drug Administration (FDA) is no exception. Significant budget cuts are impacting federal focus—and corporate requirements, expectations, and obligations—when it comes to food safety, from inspections to rulemaking efforts. Even so, there is heightened pressure globally and from the public to elevate food safety efforts. Here are some of the things KTL’s food safety experts are watching in 2026.

FDA Budget Cuts

As with most federal agencies, the FDA is not immune to reduced budgets for FY2026 under the Department of Health and Human Services (HHS). Cuts include significant reductions in staff, causing FDA leadership to shift focus to streamlining operations and relying on artificial intelligence (AI) tools to fill in gaps. It is anticipated that states may take on more responsibility for conducting routine food inspections due to the lack of federal capacity. In addition, federal budget cuts could slow progress on rulemaking initiatives, including traceability requirements, contaminant action levels, and artificial dye bans (see below).

Companies would be wise to continue treating proactive food safety management as a strategic investment, not a compliance cost, and maintain federal-level food safety compliance readiness, regardless of inspections and enforcement.

Tip: Strengthen internal food safety management systems (FSMS) to prepare for potentially more strict state standards. Prioritize internal audit, environmental monitoring, supplier management and verification, and corrective action programs. Maintain compliance calendars and clear records and documentation.

FDA Regulatory Updates

As noted above, budget cuts are impacting finalization and implementation of several key FDA rules, several of which have been in progress for years.

Food Traceability Final Rule: FSMA 204

FDA’s Food Traceability Rule remains on everyone’s radar. Originally passed in November 2022 with a compliance date of January 20, 2026, that date has been delayed until July 20, 2028. At this point, FDA remains committed to implementing the full requirements of the final rule but giving industry additional time to comply. Traceability remains a huge concern given the number of recent high-profile recalls. Employing robust traceability processes is vital for reducing risks, regardless of regulatory requirements.

Tip: Develop records for capturing Key Data Elements (KDEs) associated with Critical Tracking Events (CTEs). Perform traceability exercises and mock recalls to help identify gaps in testing protocols, verification processes, corrective action implementation, and overall adequate traceability processes. Invest in a good technology solution that integrates with the FSMS to streamline the traceability process.

California AB 660 “Sell by” Ban

Open date labeling (e.g., “best if used by”, “sell by”, “expires on”, “freeze by”) is not currently mandated or standardized by federal law. However, the State of California has forged ahead with standardizing the use of open date labeling on food products. Beginning July 1, 2026, California AB 660 implements the first mandatory food date labeling for companies selling food products in California. Under the new law, food products will no longer be allowed to display confusing “sell-by” or “best before” dates. Instead, food companies will use “best if used by” or “best if frozen by” to indicate peak freshness/quality and “use by” or “freeze by” to indicate when a food item is no longer safe to eat. Anticipate other states to follow California’s lead.

Tip: Understand what the various open date labeling phrases mean before applying them to products. If you currently (or intend to) sell products in California, standardize open date labeling practices to meet the new requirements by the July 2026 compliance date.

Removing Artificial Food Dyes

In April 2025, the FDA announced a series of new measures to phase out all petroleum-based synthetic dyes from the food supply by the end of 2026, including FD&C Green No. 3, FD&C Red No. 40, FD&C Yellow No. 5, FD&C Yellow No. 6, FD&C Blue No. 1, and FD&C Blue No. 2. The FDA is planning to proceed without any statutory or regulatory changes, relying instead on the voluntary efforts of the food industry in complying with its mandates to remove the synthetic dyes as quickly as possible from the market.

Tip: Inventory existing products and their ingredients to determine which products use synthetic dyes. Reformulate affected products to use natural color alternatives and identify and approve new suppliers of alternative ingredients. Update label design, adjust ingredient panels, and modify any relevant nutritional claims.

Environmental Action Levels

Since 2020, the FDA has been making progress on establishing action levels for environmental contaminants (specifically arsenic, lead, cadmium, and mercury) to reduce dietary exposure as much as possible. The Closer to Zero Initiative has prioritized foods commonly eaten by babies and young children, and in 2025, the final Guidance for Lead in foods intended for babies and young children was released. Draft guidance for arsenic and cadmium was scheduled to be drafted in 2025; however, it has been delayed. 

Tip: Integrate environmental contaminant testing for lead, arsenic, cadmium, and mercury into existing Environmental Monitoring Programs, prioritizing high-risk categories. Conduct risk assessments to determine which ingredients and products are most vulnerable to contamination. Review and strengthen supplier requirements to address environmental contaminants.

“Product of USA” Rule

Effective January 1, 2026, the U.S. Department of Agriculture’s (USDA) rule on how voluntary U.S. origin claims (e.g., Product of USA, Made in the USA) can be used on meat, poultry, and egg products became enforceable. Under the rule, companies may only use one of the claims if an animal is born, raised, slaughtered, and processed in the U.S. Note that these requirements differ for single-ingredient products vs. multi-ingredient products. Previously, imported animals/meats could use the claim if processed domestically. It is important to note that using these claims remain voluntary; however, establishments that choose to use them must maintain documentation proving U.S. origin.

Tip: If you choose to voluntarily make U.S. origin claims, ensure meat, poultry, and egg products meet the U.S. origin requirements; maintain documentation to substantiate claims; and include required descriptions on labels following updated USDA Food Safety and Inspection Services (FSIS) guidance.

Certification Updates

SQF Edition 10

Earlier in 2025, the Safe Quality Food Institute (SQFi) announced it would be releasing Edition 10 of its Safe Quality Food (SQF) Code to align with the latest Global Food Safety Initiative (GFSI) benchmarking criteria, updated regulatory requirements, and scientific changes. That release has been delayed until early March 2026 due to an extension in the GFSI benchmarking application timeline. The planned SQF Edition 10 changes focus on three critical areas: food safety culture, change management, and environmental monitoring. Pending completion of the review process, the first Edition 10 audits could begin as early as January 2027.

Tip: Assess current SQF program elements, identify improvements that are internally desirable and required by Edition 10, and implement those updates that will make the SQF program more useful to the business. 

FSSC 22000 Version 7

Food Safety System Certification (FSSC) announced in October 2025 that it is commencing the development of FSSC 22000 Version 7. The new version will focus on incorporating the updated ISO 22002 prerequisite programs (PRPs), aligning with the GFSI benchmarking requirements, strengthening requirements to support UN Sustainable Development Goals (SDGs), and providing more structure for the division of food chain categories. Release of Version 7 is anticipated at the end of Q1 or beginning of Q2 2026.

Tip: Assess current FSSC 22000 program elements against potential changes. Review PRPs (e.g., sanitation, pest control, allergen management, waste handling) and update standard operating procedures (SOPs). Consider sustainability metrics, including energy, water, and waste use to ensure SDG alignment.

Others to Watch

Dietary Guidelines for Americans 2025-2030. HSS and the USDA have published new Dietary Guidelines with the underlying message to “Eat real food.” Changes include increased recommended daily protein intake, emphasis on dairy, and the avoidance of highly processed foods. Currently, “highly processed foods” or “ultra processed foods” are not clearly defined; however, there are efforts at the state and federal levels to define and regulate the category.

PFAS “Forever Chemicals”. There is currently a patchwork of federal requirements and state-level regulations and product bans in the U.S. related to per- and polyfluoroalkyl substances (PFAS). The FDA has been working to limit PFAS in food and food packaging; in 2024-2025, the agency also committed to testing foods from the general food supply to more accurately estimate exposure to PFAS from foods. While federal regulatory efforts have slowed significantly, organizations need to stay informed, especially at the state level, and address PFAS in their operations, products, supply chains, and waste streams accordingly.

Artificial Intelligence (AI). As noted above, budget cuts are prompting the FDA to accelerate the use of AI to streamline operations and improve efficiency. Many food companies are also starting to test the limits on what AI can—and can’t—do effectively and correctly. While AI may be leveraged as a tool to aggregate data, enhance traceability and recall readiness, automate routine tasks, and draft certain documents (e.g., audit reports, inspection summaries, training materials), using AI must be done thoughtfully, as it cannot replace food safety programs and human involvement. In fact, over‑automation without expert oversight can significantly increase error and legal exposure.

Looking Ahead

As we move into 2026, it will be important to monitor status of these trends and issues, as timelines may shift without warning and states may enact their own requirements. Start preparing now, even if deadlines have been pushed back—things could change. Now is the time to:

• Reassess regulatory exposure, strengthen internal systems, and ensure food safety programs are resilient, auditable, and aligned with broader business objectives.
• Implement proactive planning, disciplined data management, and thoughtful use of technology to turn uncertainty into a competitive advantage.
• Leverage partnerships with consulting partners with deep regulatory insight and practical implementation experience to help navigate the evolving regulatory landscape, protect against emerging risks, and position your organization to sustain whatever the next regulatory cycle brings.