Food Label Changes Coming in 2027
Two dates in 2027 carry an actual labeling requirement, and only one is federal. Red No. 3 leaving the food supply on 15 January, the Texas warning statement on 1 January, and the proposals that keep being reported as though they were law.
Two dates in 2027 carry an actual food labeling requirement in the United States, and only one of them is federal. Most of what is written about food label changes 2027 is either a 2028 deadline reported early or a proposed rule reported as though it were already law. Every item below is tagged final, proposed, voluntary or state law, with the instrument that creates it and the date it bites. Anything that is a projection rather than a commitment is labelled as one.
For the wider calendar, from the 2016 Nutrition Facts rule through to the 2028 deadlines, see FDA nutrition label changes: 2026 to 2028. This page is the 2027 slice of it. Status is current as of 2 September 2026, when the underlying research was verified against the Federal Register and the eCFR.
Food label changes 2027: the items that carry a real 2027 date
Read the status column before the date column. Two entries qualify, and they are very different animals.
| Date | What changes | Status | Legal instrument |
|---|---|---|---|
| 1 Jan 2027 | Texas SB 25 ingredient warning statement, on labels developed or copyrighted on or after this date | State law, final state rule, enforcement enjoined in part | Texas SB 25; Texas DSHS final rule of 20 Feb 2026; preliminary injunction in American Beverage Association v. Paxton, W.D. Tex., 11 Feb 2026 |
| 15 Jan 2027 | FD&C Red No. 3 may no longer be used in foods and dietary supplements | Final | FDA order of 15 Jan 2025 revoking the color additive listing, under the Delaney Clause |
That is the complete list. No change to the Nutrition Facts panel format, no Daily Value change, no serving size or reference amount change, and no federal front-of-package requirement takes effect in 2027. If a source tells you otherwise, it is describing a 2028 date, a proposal, or a voluntary target.
15 January 2027: FD&C Red No. 3 leaves the food supply
This is the one genuinely federal, genuinely final 2027 date. FDA issued the order revoking the color additive listing on 15 January 2025 under the Delaney Clause. Foods and dietary supplements must stop using FD&C Red No. 3 by 15 January 2027; ingested drugs get until 18 January 2028. FDA has encouraged manufacturers to move sooner, but the deadline itself is binding.
The label mechanism matters, because "stop using an ingredient" is not the same as "reprint one line." Red 3 is a certified color additive. Under 21 CFR 101.22(k)(1), a color additive subject to certification must be declared in the statement of ingredients by the name listed in part 74 or part 82. The "FD&C" prefix and the term "No." need not be included, which is why panels read "Red 3." The term "Lake" does have to be included for a lake of a certified color, the rule's own example being "Blue 1 Lake."
Whatever replaces it is declared under a different paragraph. Under 101.22(k)(2), color additives not subject to certification, and not otherwise required by part 73 to be declared by their own common or usual names, may be declared as "Artificial Color," "Artificial Color Added," or "Color Added," or as "Colored with ..." or "... color" with the name filled in. The reformulated ingredient statement can therefore read differently in kind, not just in wording.
Three knock-on effects decide how much work the swap actually is:
- Ingredient order. 21 CFR 101.4(a)(1) requires ingredients to be listed by common or usual name in descending order of predominance by weight. Certified colors sit at the bottom because they are used at trace levels, so a like-for-like swap usually moves nothing. A replacement used at a higher level, such as a juice concentrate carrying the color, can move up the list.
- The 2 percent grouping. Under 101.4(a)(2), ingredients present at 2 percent or less by weight may sit at the end of the statement after a quantifying phrase such as "Contains 2 percent or less of." A replacement colorant that crosses the threshold you declared has to come out of that group.
- The nutrition panel. If the reformulation changes nutrient values, the panel is recalculated from the new formula, not patched. A juice-based replacement can add measurable sugars where a certified dye added none.
If the ingredient statement is being rebuilt anyway, our ingredient list formatter applies the descending-order rule and the 2 percent grouping to the revised formula.
One thing is often bundled into this deadline but is not part of it. The HHS and FDA announcement of 22 April 2025 asked industry to eliminate FD&C Green 3, Red 40, Yellow 5, Yellow 6, Blue 1 and Blue 2 by the end of 2026, alongside revoking Citrus Red No. 2 and Orange B and approving new color listings such as gardenia blue and beetroot red. That end-of-2026 element is a voluntary target, not a rule, and no compliance date attaches to it. Ingredient statements change as replacements appear, but no new label format is required.
1 January 2027: the Texas warning statement, and why it may not reach you
Texas SB 25 requires a warning statement on labels of foods containing any of 44 listed ingredients, and the Texas Department of State Health Services issued its final rule on 20 February 2026. The prescribed text is: "WARNING: This product contains an ingredient that is not recommended for human consumption by the appropriate authority in Australia, Canada, the European Union, or the United Kingdom."
Two features make this different from a federal deadline. First, the trigger is artwork, not a shelf date: the requirement attaches to labels developed or copyrighted on or after 1 January 2027, so a label already in use is not swept in on the date itself. Second, enforcement is contested. A federal court in the Western District of Texas granted a preliminary injunction on 11 February 2026 in American Beverage Association v. Paxton, blocking enforcement against the plaintiff trade associations and their members while the litigation continues. The DSHS rule also excludes ingredients that FDA or USDA have found safe.
Whether this warning is ever enforced, and whether federal preemption arguments succeed, is unresolved and should be treated as speculative. Plan around the artwork trigger and your trade association membership, not around a prediction of the outcome. And note the category: this is state law, not an FDA food label change, and it appears nowhere in 21 CFR.
What gets called a 2027 change and is not one
The front-of-package "Nutrition Info" box is proposed, not final, and has no 2027 date of any kind. FDA published it in the Federal Register on 16 January 2025 at 90 FR 5426, docket FDA-2024-N-2910; it would create a new 21 CFR 101.6, and comments closed on 15 July 2025. As of 2 September 2026 no final rule exists, so nothing has started. The proposal would give businesses with $10 million or more in annual food sales three years from the final rule's effective date, and smaller businesses four years, but that clock begins only if and when a final rule publishes.
The Unified Agenda had projected a final rule for May 2026, and that date passed with nothing published. In March 2026 FDA leadership said publicly that "everything is on the table" and that meaningful changes could require re-proposing the rule for another round of notice and comment. Doing the arithmetic anyway, a final rule published late in 2026 with a 60-day effective date would put the earliest compliance in early 2030 for large firms and early 2031 for smaller ones. Those are projections from the proposal's text, not FDA statements, and any front-of-package date is speculative. The certainty is the negative: no packaged food sold in the United States is required to carry a front-of-package box, and none will be in 2027. The proposed design and scope are set out in our front-of-package guide, written in the conditional throughout.
The tightened "low sodium" definition rides in that same proposal. It would cut the threshold from 140 mg to 115 mg or less per reference amount. It is proposed. The binding definition in 21 CFR 101.61 remains 140 mg or less, and it remains 140 mg through 2027 unless a final rule says otherwise.
The updated "healthy" claim is final, but its compliance date is 25 February 2028, not 2027. The rule was published on 27 December 2024 and took effect on 28 April 2025 after a delay. Using the claim is voluntary and stays voluntary: 2028 is when a product that chooses to bear "healthy" must meet the new criteria, not when anything must appear on every label.
The Dietary Guidelines for Americans 2025-2030, released 7 January 2026, is a guidance document, not a labeling rule. It changed no Daily Value. The values in 21 CFR 101.9 are unchanged, and changing them would require rulemaking that has not been proposed. Any article that says your percent Daily Values changed because of the Dietary Guidelines is wrong.
The federal ultra-processed food definition is not a labeling requirement. HHS and FDA sent a document titled "Proposed Definition of Ultra-Processed Food" to OMB on 3 August 2026, announced on 10 August 2026. It is described as a definition and research tool, not a proposed rule, and its criteria were not public as of 2 September 2026. Any mandatory ultra-processed label or claim standard is speculative.
A "low added sugars" nutrient content claim has not been proposed yet. The Unified Agenda projects a notice of proposed rulemaking for December 2026, and an agenda projection is not a deadline. The Food Labeling Modernization Act of 2026 is in the same category: introduced in both chambers, not enacted, no legal effect.
What a producer should actually be doing in 2027
Almost all of the real work in 2027 is preparation for two dates in 2028. The point of separating final from proposed is that it tells you where to spend artwork budget, and the answer is not the front-of-package box.
Clear Red 3 before 15 January 2027. Audit by SKU rather than by brand, because a single flavour variant is the usual place a certified color survives. Sequence the reformulated artwork into a print run you were doing anyway, and remember that the change is not only the color line: check the ingredient order and the 2 percent grouping, and recalculate the panel if the formula moved.
Work back from 1 January 2028, the uniform compliance date. FDA's final rule of 31 December 2024 set 1 January 2028 as the uniform compliance date for food labeling regulations published between 1 January 2025 and 31 December 2026 that do not set their own date. That is the reason to batch: qualifying rules converge on one date, so a single artwork cycle in 2027 can absorb several small changes.
Work back from 25 February 2028 if you use the word "healthy." Inventory the term and its derivatives first, since 21 CFR 101.65(d)(3) reaches "health," "healthful," "healthier" and the rest when used as an implied nutrient content claim. For each product, confirm the food group equivalent minimum for its category and the limits on added sugars, sodium and saturated fat, or confirm that it is an automatic qualifier. Then start the paperwork: 101.65(d)(4) requires written records verifying food group equivalent content, kept for at least two years after the food enters interstate commerce, unless that content is evident from the label or the product is an automatic qualifier. The criteria by category are set out in the healthy claim requirements guide. A product that fails is not a 2028 emergency if you find it in 2027, it is a reformulation with eighteen months of runway.
Do one thing about front-of-package, and only one. Make sure the percent Daily Values for saturated fat, sodium and added sugars on your existing panels are right, because the proposed box would reuse exactly those figures as already calculated and rounded for the Nutrition Facts label under 101.9(c)(9) and (d)(7)(ii). That holds whether the box is finalised, withdrawn or re-proposed, which makes it the only defensible front-of-package spend in 2027.
If that audit turns up a panel that needs rebuilding from the formula rather than patching, the nutrition label generator will take the revised recipe and produce the compliant panel and ingredient statement together.
Frequently asked questions
What food label changes actually take effect in 2027?
Two. On 15 January 2027 FD&C Red No. 3 may no longer be used in foods or dietary supplements, under FDA's order of 15 January 2025 revoking the color additive listing. On 1 January 2027 the Texas SB 25 warning statement attaches to labels developed or copyrighted on or after that date, although that is state law and a federal court has blocked enforcement against the plaintiff trade associations and their members. Nothing about the Nutrition Facts panel itself changes in 2027.
Will the front-of-package label be required in 2027?
No. The front-of-package "Nutrition Info" box is a proposed rule, published 16 January 2025 at 90 FR 5426, and no final rule had been published as of 2 September 2026. The compliance clock in the proposal, three years for larger businesses and four for smaller ones, does not start until a final rule takes effect. FDA has committed to no date and has signalled it may revise or re-propose the rule, so any specific front-of-package date you read is speculation.
Do I have to stop using Red 3 in 2027?
Yes, for food and dietary supplements, by 15 January 2027. This is final, not voluntary. Ingested drugs have until 18 January 2028. The other petroleum-based dyes are a different matter: the end-of-2026 removal of Green 3, Red 40, Yellow 5, Yellow 6, Blue 1 and Blue 2 is a voluntary target announced on 22 April 2025, not a regulation, and carries no compliance date.
Is the "healthy" claim deadline in 2027?
No, it is 25 February 2028. The rule is final and in effect, and manufacturers may use the new criteria now, but 25 February 2028 is the date by which a product bearing "healthy" or a derivative term must meet the updated definition in 21 CFR 101.65(d). Products that do not use the claim are unaffected on that date and every other date.
Did the 2025-2030 Dietary Guidelines change the Daily Values on my label?
No. The Dietary Guidelines for Americans 2025-2030, released 7 January 2026, is a guidance document. The Daily Values in 21 CFR 101.9 are unchanged, and changing them would require a rulemaking that has not been proposed. FDA has said only that it will assess whether the "healthy" criteria need aligning with the guidelines, which is not the same as changing a Daily Value.
Does the Texas warning apply to my label on 1 January 2027?
Only if the product contains one of the 44 listed ingredients and the label is developed or copyrighted on or after that date. Ingredients FDA or USDA have found safe are excluded under the Texas DSHS rule. Enforcement is also blocked against members of the trade associations that sued, under the preliminary injunction of 11 February 2026, and the litigation is unresolved. Treat the eventual outcome as genuinely uncertain rather than assuming either result.
