Food Safety's Slalom Course of 2025
Dr. David Acheson, FDA's former associate commissioner for foods, annually provides us with a two-part look back/look ahead at food safety & regulatory affairs. His predictions for 2026 can be found here.
Last year about this time, I predicted that 2025 would be a year of change. While that certainly came to pass, especially at the federal food agencies, it was a mixed bag as to how much that change resulted in action or in impact on the food industry.
There was an entirely new administration with a sweeping change in ideology and significant personnel cuts and shuffling; and there was a heavy focus on eliminating artificial dyes, ultraprocessed foods and self-affirmed GRAS, all intended to Make America Healthy Again.
But as 2025 closed out, there was little to no solid FDA action or regulation taken on these. The phase-out of artificial dyes has become an “encouraged” but voluntary industry initiative; ultraprocessed foods are struggling to be defined; and the elimination of self-affirmed GRAS is under “exploratory” rulemaking.
On the other hand, the FDA did advance some initiatives in 2025 such as:
- Granting approval of some natural-sourced color additives that could be used by manufacturers to replace the synthetic, petroleum-based dyes that have been under pressure to be banned.
- Implementing a revised definition and criteria for voluntary use of the “healthy” claim on food labels to align it more closely with current nutrition science and dietary guidelines.
- Revoking or proposing revocation of food standards determined to be obsolete and no longer applicable or necessary
- Publishing a final rule on the pre-harvest agricultural water provision of FSMA’s Produce Safety Rule.
Structurally, there was a great deal of shuffling in the agency. Not only was FDA reduced in personnel through reductions in force, voluntary “encouraged” resignations and early retirements, but the National Advisory Committee on Microbiological Criteria for Foods (NACMCF) and the National Advisory Committee on Meat and Poultry Inspection (NACMPI) – on which the USDA, FDA and CDC had extensively relied for impartial advice and recommendations – were completely eliminated.
The administration also announced a planned restructuring that would consolidate the 28 divisions of HHS into 15. However, that plan, which was announced in March, has not yet been implemented, and in December a Congressional bill to consolidate food oversight into a single agency was reintroduced.
While the proposal would not unite FDA and USDA, it would pull the food divisions out of FDA into a stand-alone agency under HHS, with a separate Foods Commissioner. Whether either of these reforms will be implemented is yet to be seen, but they are sure to continue as discussions in 2026.
The public health side was just as tumultuous, with the complete overhaul of the CDC Advisory Committee on Immunization Practices (ACIP) – which guides the nation’s immunizations policies. As a result, a number of vaccine schedules and recommendations have been shifted, though not without a great deal of controversy.
At the USDA, it was, more or less, business as usual, but there’s not been much forward momentum there either. In fact, it withdrew its proposed rule to reduce salmonella in raw breaded poultry products, kicking its decision on an approach to address the issue down the road. The reasoning behind it was the number of issues raised in public comments including whether FSIS has legal authority to propose final product standards, the scientific and technical information used to support the framework, the potential economic impacts and whether the proposed 1 CFU salmonella can even be detected in breaded chicken products.
If you take all these shifting, pending, and controversial initiatives and add the ever-changing tariffs and their impacts on the industry, the increased focus on imports and shift to unannounced foreign inspections, and the general MAHA swing in ideology, it sums up to show 2025 to have been a rather turbulent year.
The food industry had to be ever on its toes, ready to make quick turns while not receiving actual regulations to guide the slalom-like course that was being laid.
Dr. David Acheson, FDA's former associate commissioner for foods, is founder and CEO of The Acheson Group, a consulting firm with a focus on food safety and risk management. This article is from a TAG article; used with permission.