Key takeaways:
- Ingredient transparency in the US has shifted from a voluntary ‘clean label’ trend to a layered regulatory, political and reputational pressure point for manufacturers.
- As scrutiny expands from individual additives to processing itself, reformulation becomes more complex, costly and operationally disruptive.
- Without coordination across regulators, retailers and public discourse, rising transparency demands risk creating system fragility rather than greater clarity.
For much of the past decade, ‘clean label’ operated as a market signal rather than a compliance framework. Brands responded to growing consumer discomfort around artificial additives and unfamiliar chemical names by gradually refining recipes, shortening ingredient lists and reconsidering certain colourings or preservatives. It wasn’t always straightforward, but it was largely manageable because the pace of change remained within the industry’s control.
The phrase was never defined in law – and it didn’t need to be.
“There is no single, universally accepted definition of clean label,” Stephanie Mattucci, principal strategist at Mintel, said. “But it is widely understood as products made with familiar ingredients and free from artificial additives.”
That absence of formal definition created space. Manufacturers could interpret ‘clean label’ in ways that aligned with their technical capabilities and commercial timelines, while consumers interpreted it according to their own expectations. Regulators observed but didn’t intervene.
However, that equilibrium has become harder to sustain. In 2026, transparency is no longer shaped primarily by shopper preference; federal scrutiny, state-level disclosure proposals, retailer ingredient policies and a more politicised debate about food processing have converged. Each pressure point might be navigable on its own. In combination, they alter the operating environment.
The argument has widened
Earlier this year, the US Food and Drug Administration (FDA) said it would exercise enforcement discretion around certain ‘no artificial colour’ claims for products that don’t contain FD&C certified colours – synthetic dyes approved and batch-certified by the FDA – including Red No 40 and Yellow No 5 (tartrazine). Although the announcement was framed as guidance, it reflected a shift in tone. Synthetic dyes, long treated as functional tools of formulation, now sit in a more politically charged space.
The Generally Recognized as Safe (GRAS) framework has also come back into view. During a February segment on 60 Minutes, US Health and Human Services Secretary Robert F Kennedy Jr described GRAS as a statutory ‘loophole’ dating back to 1958, arguing that it’s enabled widespread use of industrial ingredients without premarket review by the FDA. Former FDA Commissioner David Kessler has similarly questioned whether certain refined carbohydrates should continue to qualify under GRAS.
What’s striking is how quickly the discussion has evolved. It’s moved beyond the presence or absence of a specific additive and now centres on how foods are designed, processed and classified.
Kantha Shelke, principal at Corvus Blue and senior lecturer at Johns Hopkins University, has cautioned against reducing the discussion to a simplistic good-versus-bad narrative. She’s emphasised that processing itself isn’t inherently harmful and that the term ‘ultra-processed’ can obscure important distinctions between functionality, safety and nutritional quality. Many ingredients criticised in public discourse, she argues, serve essential technological purposes – from ensuring microbial safety to maintaining texture and stability.
“Most of the studies linking UPFs to negative health outcomes are observational. They don’t prove causation, but media and policy treat them as if they do,” she said, adding: “Pasteurisation, fermentation, fortification – these are technologies that have improved public health for generations. Treating all processing as suspect undermines consumer trust and food safety.”
Shelke has also warned of unintended consequences. “Consumers are now avoiding fortified cereals, enriched breads and shelf-stable baby foods because they fear ‘chemicals’ or ‘ultra-processing’. That’s dangerous,” she said.
Leo Campbell, co-founder of Superloaf and former R&D executive at Hovis, makes a similar point. Processing, he argues, is a tool. It can improve safety and accessibility or contribute to over-engineered formulations, depending on how it’s used. Blanket categorisation does little to help manufacturers or consumers make more informed decisions.
“We’ve let a manufacturing label stand in for public health. It’s like blaming the printing press for bad novels,” Campbell said. “When we demonise processing, we’re cutting off one of the best tools we have to make food healthier at scale.”
If the debate shifts from ‘what’s in it?’ to ‘how was it built?’, the implications widen considerably. Reformulation has long been the industry’s default response to pressure. It becomes far more complicated when scrutiny extends to the architecture of modern food production itself.
The uncomfortable contradiction
At the same time that additives and processing are being scrutinised, agricultural chemicals are being defended at the highest level of government as economically indispensable.
In February, President Donald Trump signed an executive order titled Promoting the National Defense by Ensuring an Adequate Supply of Elemental Phosphorus and Glyphosate-Based Herbicides. The order states that there is “no direct one-for-one chemical alternative to glyphosate-based herbicides” and argues that restricting access would “critically jeopardize agricultural productivity”, reduce yields and push up food prices.
The federal message is clear: that glyphosate underpins agricultural stability. Yet in the same month, Florida officials – including Governor Ron DeSantis, First Lady Casey DeSantis and State Surgeon General Dr Joseph Ladapo – publicised glyphosate residue testing results in supermarket bread as part of the state’s health initiative. Detectable levels were found in multiple products, although all fell below Environmental Protection Agency (EPA) thresholds.
Both positions operate within existing federal safety standards but they emphasise different risks. Florida’s framing highlights chemical presence in finished foods. The executive order highlights the consequences of restricting the chemical used to produce them.
Marion Nestle, professor emerita at New York University and author of Food Politics, described the federal move as “hypocrisy in action,” noting that glyphosate residues are widely detected in staple foods, including bread.
RFK Jr later defended the administration’s stance on social media, writing that the US agricultural system “depends heavily on these chemicals” and warning that eliminating them overnight would be “disastrous.”
For manufacturers, the signal is layered. Residue data is amplified at state level. Input stability is reinforced at federal level. The regulatory thresholds haven’t changed; the political emphasis has.
Pressure builds in layers
Federal scrutiny is only part of the picture. States including California, New York and New Jersey are considering additional reporting requirements tied to GRAS determinations. Retailers add further complexity. Large US chains operate restricted ingredient lists that sometimes go beyond federal requirements, and those lists evolve quickly when an ingredient becomes the focus of public criticism.
The result is a complicated picture: an ingredient can remain legal while becoming commercially sensitive. For manufacturers, that means navigating multiple standards at once. A formulation acceptable to the FDA may need modification for a key retailer. A label compliant nationally may require adjustments in a specific state.
None of this is dramatic, but it accumulates. Administrative burden absorbs time, money and attention.
Social media has added a new layer of volatility. Ingredient call-outs now function as crowd-sourced regulation, with creators zooming in on unfamiliar additives and framing them as red flags. Scientific nuance doesn’t travel well in that format. What’s legally compliant and technologically necessary can still become commercially toxic if it trends for the wrong reasons.
For smaller brands, a single forced reformulation can disrupt supplier contracts and cash flow. For larger companies, scale turns single-ingredient debates into portfolio-wide projects. From the outside, this may appear incremental. Internally, it translates into reformulation trials, supplier renegotiations, revised specifications and packaging updates. Innovation doesn’t stop, but it competes for resources.
The dynamic isn’t uniquely American, even if it’s particularly politicised there. In Europe, the European Food Safety Authority’s (EFSA) precautionary approach to additives has long shaped reformulation strategies, while front-of-pack labelling debates continue to influence ingredient decisions. In the UK, HFSS (high in fat, sugar and sodium) restrictions and advertising rules have already forced product redesigns. In parts of Latin America, mandatory warning labels have altered formulation incentives. The regulatory architecture differs by region, but the underlying pattern is similar: transparency expectations are expanding faster than manufacturing systems were originally built to accommodate.
Reformulation and its limits
The move away from certified FD&C colours illustrates how parts of the sector are trying to anticipate change rather than react belatedly. The American Bakers Association (ABA) formalised that approach through its Baked Goods FD&C Colours Pledge in late 2025.
Eric Dell, ABA president and CEO, said: “By uniting around this pledge, our members are building on their progress in this space, going beyond what’s required and responding to evolving consumer desires.”
That kind of coordination may reduce uncertainty, but it doesn’t make the technical work frictionless. Natural colour systems don’t replicate synthetic performance exactly, and agricultural supply introduces different volatility. As more manufacturers transition at once, those differences become more pronounced.
Renee Leber, food scientist and technical services manager at the Institute of Food Technologists (IFT), said companies are using dye transitions as a chance to revisit broader formulation choices. “While transitioning away from synthetic colour usage is a major focus across the food industry, I’ve seen companies use this change to make broader formulation updates… with some using the opportunity to move products toward a clean label position.” She noted that substitutions must be evaluated carefully for functionality and cost, particularly in baked goods and snacks where colour interacts closely with texture and processing.
Reformulation can address perception. It doesn’t necessarily simplify the underlying system.
Where transparency strains infrastructure
Behind every ingredient list sits traceability data, supplier documentation and regulatory records. The FDA’s Food Traceability Rule raises expectations around how that information is captured and shared. Retail partners increasingly expect rapid access to similar data.
As disclosure requirements expand, systems get tested. Gaps that once remained internal can quickly become liabilities.
Transparency itself isn’t controversial. What creates strain is fragmentation. When federal scrutiny, state initiatives, retailer policies and public activism intensify without coordination, the cumulative effect is operational drag. What begins as clarity can, if layered without alignment, become friction.
The US industry has navigated reformulation cycles before. What feels different now is the layering. When every ingredient carries regulatory, political and reputational weight at once, transparency stops being a brand story and becomes an infrastructure question.
Infrastructure moves slowly. Politics and social media don’t. And that’s where operational chaos begins.