19
Feb
Food Safety
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On October 1, 2024, the Food and Drug Administration (FDA) began implementing the largest reorganization in the Agency’s recent history, including launching a unified Human Foods Program (HFP) to oversee all activities related to food safety and nutrition. The HFP was designed to help ensure that the FDA-regulated food supply is safe by taking a systematic, risk management approach to implementing the preventive measures outlined in the Food Safety Modernization Act (FSMA) and responding to food-related emergencies. Specifically, the HFP’s mission is to protect and promote the health and wellness of all people through science-based approaches to prevent foodborne illness, reduce diet-related chronic disease, and ensure chemicals in food are safe.
Priority Deliverables
On January 23, 2026, FDA released its priority deliverables and guidance agenda for 2026 to further advance HFP’s vision and mission within the program’s three focus areas:
- Food Chemical Safety focuses on ensuring exposure to chemicals and additives that occur in foods is safe.
- Microbiological Food Safety focuses on the oversight of industry’s efforts to ensure the safety of the foods they produce and to prevent foodborne illness.
- Nutrition promotes FDA’s Make America Health Again (MAHA) strategy and focuses on reducing chronic disease through better nutrition.
The table below outlines the 2026 priority deliverables for each of these areas. Several of these are also discussed in more detail in KTL’s recent article on 2026 Food Safety Trends to Watch.
| Priority Deliverable | HFP Actions |
| FOOD CHEMICAL SAFETY | |
| Generally Recognized as Safe (GRAS) Reform | Publish a proposed regulation requiring entities to submit GRAS notices for all new substances claimed to be GRAS before they are introduced into a human or animal food substance. |
| Post-Market Safety Reviews of Marketed Food Chemicals | Continue reassessing chemicals used in foods, starting with those most concerning to consumers; post a Systematic Post-Market Assessment process. |
| Microplastics | Conduct research to identify ways to accurately detect, quantify, and characterize microplastics in human food. |
| Closer to Zero | Establish action levels for cadmium and inorganic arsenic in baby and toddler foods; issue guidance on preventive controls to minimize chemical hazards in all foods. |
| Natural Color Additives | Continue phasing out petroleum-based food dyes and completing reviews of new natural alternatives. |
| Consumer Exposure to Contaminants in Food | Continue studying exposure to certain heavy metals, per- and polyfluoroalkyl substances (PFAS), and other contaminants in food. |
| Regulation of New Dietary Ingredients | Release final guidance regarding safety and identify information required for new dietary ingredient (NDI) notifications; develop methods to streamline FDA’s review of NDI notifications. |
| Dietary Supplement Oversight | Evaluate modernized approaches to support dietary supplement priorities with targeted enforcement strategies on violative products. |
| Guidelines for Caffeine Labeling | Promote best industry practices for labeling added caffeine content in both packaged foods and beverages and those in retail and restaurant settings. |
| Allergen Labeling | Develop recommendations for transparency in disclosure of ingredients that impact certain health conditions and other established food allergens. |
| MICROBIOLOGICAL FOOD SAFETY | |
| Food Inspection Coverage | Create Better Regulatory Inspections for Dynamic Government Efficiency (BRIDGE) by relying on state partners to carry out routine food safety systems inspections based on FDA’s national standards. |
| National Regulatory and Laboratory Training System | Build a sustainable training system and standards for all Integrated Food Safety System (IFSS) regulatory and laboratory professionals, including establishing the National Coordination Center to implement consistent training standards for federal and state regulatory and laboratory staff. |
| Oversight and Safety of Imported Food | Enhance the ability to identify and act on violative products and ensure imported food meets the same food safety standards as food produced domestically; expand allocation of inspectional, laboratory, and other oversight resources to the foreign arena; enforce Import Certification and Foreign Supplier Verification Program (FSVP) requirements. |
| Imported Seafood Safety | Continue emphasis on sampling shrimp supply chains for compliance to ensure the safety of imported shrimp and complete development of a seafood fraud identification program. |
| Fresh and Processed Produce Safety | Improve the safety of fruits and vegetables through numerous activities including advancing training through the Produce Safety Alliance; new training for sprout producers; new cantaloupe, leafy greens, and cucumbers initiatives; and various studies of potential hazards in produce. |
| Dairy and Egg Safety | Promote contamination through enhanced training and education for dairy and egg producers. |
| Recall Process Modernization | Explore risk communication strategies to enhance public access to critical recall information; continue to improve the speed of recall classification through process improvements. |
| Food Traceability | Work with entities to ensure they can comply with the Food Traceability Rule by the July 2028 compliance date, including facilitating tabletop exercises to test readiness and providing explanatory Q&As. |
| Food Code and Retail Program Standards | Release an updated Food Code and Retail Program Standards Manual as models for local, state, and tribal regulators to update their food safety rules and programs. |
| Tech-enabled Advances in Risk Management | Increase the information and quality of data available to establish sound risk management strategies by developing a plan to use AI predictive models to analyze large datasets and examining the application of external third-party audit data to optimize FDA resources. |
| NUTRITION | |
| Ultra-Processed Foods (UPFs) | Develop a federal government definition of UPFs and work to better identify and reduce risks associated with high consumption of UPFs. |
| Infant Formula Safety (Operation Stork Speed) | Begin implementing the plan to modernize infant formula nutrient requirements and expand options for safe, reliable, and nutritious infant formula. |
| Nutrition Regulatory Science Program | Working with the National Institute of Health (NIH), advance key research to guide food and nutrition policies to improve American’s diets and overall health (e.g., impacts of UPFs and food additives, role of maternal and infant dietary exposures on health outcomes). |
| Front-of-Package (FOP) Nutrition Labeling | Advance proposed regulation requiring food packages to display key information (e.g., added sugar, sodium levels) on the front of packages. |
| “Healthy” Claim Implementation | Implement the criteria finalized in 2025 that allows foods that meet certain standards to voluntarily use the “healthy” label claim and issue related guidance. |
| Food Standards of Identity | Complete an interim final rule, two new final rules, and several new proposed rules to continue eliminating 52 obsolete food standards of identity that describe in detail what a food must contain and what is optional in its formulation/production. |
| Added Sugar Reduction | Create an added sugar reduction strategy to encourage the food industry to lower added sugar in processed and prepared foods, including proposing a nutrient claim for added sugars and investigating ingredient and menu labeling requirements. |
| Sodium Reduction | Conduct a formal evaluation of Phase I voluntary targets under FDA’s voluntary sodium reduction initiative; encourage industry to reduce the sodium content of products. |
| Food Labeling for Online Grocery Shopping | Issue draft guidance on food labeling for online grocery shopping to increase transparency. |
| Guidelines on Direct Marketing of Certain Foods to Children | Explore development of potential industry guidelines to limit direct marketing of certain unhealthy foods to children. |
HFP also intends to develop and/or revise guidance documents on a number of topics related to food chemical safety, microbiological safety, and nutrition.
Meeting FY2026 Priorities
As we move into 2026, it is important that facilities review and understand the HBP priorities and compliance expectations for FY2026 compared to internal programs, protocols, etc.—and then make any required updates to ensure alignment. This may include the following actions:
- Educate staff to get a deeper understanding of products/operations and the associated regulatory changes and developments FDA has planned for FY2026.
- Reassess regulatory exposure, strengthen internal systems, and ensure food safety programs are resilient, auditable, and aligned with broader business objectives in light of the FY 2026 HFP priorities.
- Implement key actions, where possible, to meet impending requirements, for example:
- Perform traceability exercises and mock recalls to help identify gaps in testing protocols, verification processes, corrective action implementation, and overall adequate traceability processes.
- Inventory existing products and their ingredients to determine which products use synthetic dyes and reformulate with natural color alternatives.
- Integrate environmental contaminant testing for lead, arsenic, cadmium, and mercury into existing product testing protocols, prioritizing high-risk categories.
- Evaluate nutrition labels for required changes
- 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 manage the HFP priorities for 2026 and beyond.