Understanding what's coming to food safety in 2025 starts with a look back at the year we just ended — and what a year 2024 has been. Just some of the major food safety changes we saw in 2024 included:
- Brominated Vegetable Oil (BVO) was banned: The USFDA revoked regulations permitting the use of BVO in food and beverages, effective as of August 2. The decision was based on studies linking the ingredient to adverse health effects, but most large beverage companies had stopped using it before the change was enacted.
- Food Traceability Final Rule was introduced: Introduced under Section 204 of the Food Safety Modernization Act (FSMA), the new rule establishes a Food Traceability list and requires facilities working with foods on that list to comply with enhanced record-keeping requirements to ensure quicker and more effective recalls in case of contamination. The rule doesn't go into effect until 2026, but preparations should start as soon as possible.
- Sesame was still causing headaches for manufacturers: In 2023, sesame was added to the list of Major Allergens, bringing it up to nine from its original eight. Sesame is widely used in food manufacturing, and the change has created something between a scramble and a panic in many facilities. Throughout 2024, this led to controversial decisions about ingredient inclusion and appears to be leading up to a tense confrontation between producers and the FDA.
- Food safety went local: California passed regulations banning the use of Red Dye No. 3 (along with BVO, propylparaben, and potassium bromate), a move the state had widely signaled was likely coming. What wasn't signaled was the growing feeling in governors' mansions and statehouses that food safety should be spearheaded by the states. This trend could continue and accelerate, especially as several states prepare for confrontations with the incoming administration.
- The FDA reorganized its Human Foods program: A major reorganization of how the FDA works began and will be continuing for some time. The purpose of the reorg was to create a more efficient, safer, and capable regulatory and enforcement body. Whether this turns out to be a full renovation or just a redecoration remains to be seen.
- The FDA began full enforcement of the Food Defense rule: The Food Defense rule has been in place for some time now, but prior to September of 2024, it had only been partially enforced. September marked a change, with the FDA moving from less formal spot checks to full inspections and audits.
- New administration elected, new priorities to come: The U.S. presidential election saw a major shift happen in Washington, as Republicans led by Donald Trump managed to secure all three branches of government. While there's still a lot of uncertainty about priorities and directions the new administration will take, the early pick of Robert F. Kennedy Jr. to lead HHS can potentially offer some insights.
What's coming in food safety in 2025?
Even for an election year, 2024 was packed on the food safety compliance and regulation front. With all that happened, it can be hard to imagine 2025 being a busier year, but all indications point to exactly that. Here are the biggest changes coming to food safety in 2025:
- The FDA could follow California: The FDA is currently reviewing rules to ban Red Dye No. 3 after it was banned by California. If it does, it will have validated California's choice to press the issue with a state ban and may encourage other states to legislate food safety as a way of pressuring the FDA to move faster on food safety issues. For food manufacturers, this can lead to a frustrating situation that further fragments the nation's regulatory environment and forces unpredictable and sometimes contradictory compliance measures.
- The USDA will begin efforts to crack down on Salmonella: The USDA is taking Salmonella seriously as a partner of the CDC's Healthy People 2030 plan to reduce foodborne illness. New rules proposed by the USDA will make it illegal to sell poultry that has Salmonella levels above new lower thresholds, as well as require producers and processors to implement microbial testing programs. An updated version of the proposed policy is expected in mid-2025, though the final rule will not likely go into effect for several years.
- The new administration will set new priorities: What can we expect from RFK Jr. as the head of the FDA? While the coverage of his nomination has mainly focused on his stance on vaccines and human medicines, Kennedy has long been an outspoken critic of America's food safety regulations. While it's impossible to predict the future, especially in the complex bureaucracy of federal regulations and rule-making, we can expect that Kennedy will likely use his position to advance his long-championed causes: food additives, over-processing, and the influence wielded by food producers on policymaking.
- Uncertain priorities will emerge from Project 2025: As with Kennedy as Secretary of HHS, this will be a "wait-and-see" change. Project 2025, the plan created by conservative groups and lobbyists, is more famous for proposed impacts elsewhere, but it has a number of plans for food safety compliance and regulation. Some notable goals include repealing federal dietary guidelines, removing labeling requirements for genetically modified foods, and a general decrease in federal regulation and oversight. It's impossible to say how much influence the plan will have with the new administration in power, but it's worth looking through to understand what changes may be coming.
