FDA Releases its Human Foods Program 2026 Priority Deliverables and Guidance Agenda

On January 23, 2026, FDA released its Human Foods Program (“HFP”) 2026 priority deliverables and guidance agenda, outlining a set of regulatory and policy initiatives intended to deliver on HHS Secretary Robert F. Kennedy, Jr.’s Make America Health Again (“MAHA”) agenda and “make the U.S. food supply safer and its population healthier.”

The program will focus on three areas: (1) food chemical safety, (2) reducing chronic disease through better nutrition, and (3) microbiological food safety. Below we highlight HFP’s key initiatives:

Food Chemical Safety

• GRAS Reform: FDA will propose a rule to require the submission of notices for all substances claimed to be Generally Recognized as Safe (“GRAS”). Since December 1, 2025, the draft rule has been under review by the Office of Management and Budget (“OMB”). Deputy Commissioner for Human Foods Kyle Diamantas has previously offered brief comments on what the new rule could entail, though it remains unclear whether those elements are reflected in the draft currently under OMB review.
• Post-Market Review of Food Chemicals: HFP will continue to assess chemicals used in food that are of “most concerning to consumers” such as phthalates, propylparaben, butylated hydroxyanisole (“BHA”), and butylated hydroxytoluene (“BHT”). The agency released a prioritization tool last year and plans to release this year the first edition of the Systematic Post-Market Assessment process that will explain how it evaluates the safety of substances and decides which substances to review.
• “Closer to Zero”: HFP will establish action levels for cadmium and inorganic arsenic in baby and toddler foods, and issue guidance on preventive controls to minimize chemical hazards.
• Color Additives: FDA announced last year plans to phase out three synthetic food dyes in 2025 and the remaining six in 2026. HHS Secretary Kennedy reiterated this goal during his “Take Back Your Health” tour through Pennsylvania stating the Administration intends to “get[] rid” of the remaining six synthetic food dyes this year. FDA will also publish a draft guidance on when fruit- and vegetable-derived juices qualify as color additives under FDA regulations and prioritize review of new natural color submissions.
• Dietary Supplements: HFP will continue its release of final guidance on new dietary ingredient (“NDI”) notifications “to better inform industry on the safety and identity information required” for such notifications, and develop methods to better streamline its review process. In addition, HFP “will evaluate new and modernized regulatory approaches that protect the public health while supporting a responsible dietary supplement industry.”
• Caffeine Labeling: HFP will outline “industry best practices” for labeling added caffeine content in both packaged foods and beverages at retail and restaurant settings. A guidance related to caffeine labeling, however, does not appear on HFP’s 2026 guidance agenda.
• Allergen Labeling: FDA will gather information from stakeholders to “advance” its “approach to regulating food allergens to benefit the public health.” For example, FDA will host a listening session next month on food allergen thresholds and it recently issued a Request for Information (“RFI”) related to gluten labeling and preventing cross-contact.

Reducing Chronic Disease Through Better Nutrition

• Ultra-processed Foods (“UPFs”): FDA will continue to gather information on UPFs, including reviewing comments from its 2025 RFI. Notably, the recently released 2025–2030 Dietary Guidelines for Americans (“DGAs”) recommend avoiding “highly processed packaged, prepared, ready-to-eat, or other foods that are salty or sweet” and “sugar-sweetened beverages, such as soda, fruit drinks, and energy drinks.”
• Infant Formula: HFP will implement a plan for modernizing infant formula nutrient requirements based on information it received as part of Operation Stork Speed, and it will “release exposure data” on heavy metals and other contaminants, including lead, arsenic, cadmium, mercury, and PFAS.
• Front-of-Package (“FOP”) Nutrition Labeling: HFP will prepare options for the final FOP regulation based on public comments received on the proposed rule, which HFP describes as providing “widespread support for FOP labeling,” but with “varying opinions on the details of the label’s content and design.” Because the draft rule was largely developed under the previous Administration, it remains to be seen whether this Administration will seek to reshape the regulation, especially in light of the latest DGAs.
• “Healthy” Claim: HFP notes that it will assess whether changes to the “healthy” rule are needed to align with the latest DGAs and it will “continue work to implement the updated criteria, including by advancing a potential guidance that identifies a symbol to depict the ‘healthy’ claim.” HFP’s 2026 guidance agenda, however, does not currently include such guidance.
• Food Standards of Identity: HFP will issue an interim final rule, two new final rules, and new proposed rules related to the continued elimination of “outdated standards of identity.”
• Added Sugar Reduction: The latest DGAs emphasized that “no amount of added sugars or non-nutritive sweeteners is recommended or considered part of a healthy or nutritious diet.” HFP will implement “an added sugar reduction strategy” to encourage industry to lower added sugar in processed and prepared foods by, among other things, proposing a nutrient content claim for “low added sugar,” “investigating ingredient labeling and menu labeling requirements,” and assessing the use of low or no-calorie and non-nutritive alternative sweeteners.
• Sodium Reduction: While the DGAs contained little emphasis on reducing sodium intakes, HFP will conduct a formal evaluation of the Phase I sodium reduction targets issued in 2021.
• Direct Marketing to Children: FDA will collaborate with the Federal Trade Commission (“FTC”) to explore the development of industry guidelines and other strategies to limit “the direct marketing of certain unhealthy foods to children, as outlined in the MAHA Strategy.”
• Online Grocery Shopping: Given the dramatic rise of online grocery shopping in recent years, FDA plans to issue draft guidance on Nutrition Facts, ingredient, and other food labeling for online grocery shopping.

Microbiological Food Safety

• Better Regulatory Inspections for Dynamic Government Efficiency (BRIDGE): HFP plans to rely increasingly on state partners to conduct routine food safety inspections through a new initiative it calls “BRIDGE,” which is intended to enable FDA “to focus its resources toward international, and high-risk, complex, and targeted inspection activities.”
• Recalls: FDA intends to improve the speed of its recall classifications and risk communication strategies based on feedback from stakeholders.
• Food Traceability: HFP will continue helping stakeholders prepare for compliance with FDA’s food traceability rule, including through quarterly stakeholder engagement and completion of a tabletop exercise on traceability readiness. The agency has proposed extending the compliance date for this rule to July 20, 2028, and Congress recently directed FDA not to enforce the rule until that date. The agency is also developing a draft Q&A guidance on the traceability rule.
• Oversight and Safety of Imported Food: FDA plans to strengthen oversight of imported foods in 2026 by using improved data analytics, including artificial intelligence (“AI”)/machine learning (“ML”), and leveraging programs such as Import Certification and the Foreign Supplier Verification and the work of foreign competent authorities charged with the safety of foods imported into the United States. The Food Safety Partnership with Mexico and other Systems Recognition initiatives will be a priority.
• Imported Seafood Safety: FDA also plans to strengthen its imported seafood oversight by expanding regulatory partnerships with major exporting countries such as India and Ecuador, increasing surveillance and compliance sampling, and building whole‑genome sequencing and data‑sharing systems for shrimp supply chains. In addition, FDA will finalize a seafood fraud detection program and continue seeking new authority from Congress to mandate destruction of imported seafood that poses significant public‑health risks.
• AI Initiative: HFP will develop a plan for using AI‑driven predictive models and external third‑party audit data to analyze large, cross‑sector food‑supply‑chain datasets. The results will help FDA target oversight resources and establish risk management strategies. 

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