The 2028 FDA Food Labeling Compliance Date
There are two 2028 dates: 25 February for the updated healthy claim, and 1 January as the uniform compliance date for rules published in 2025 and 2026. What a uniform compliance date actually does, and what is not on a 2028 clock.
Search for the FDA food labeling compliance date 2028 and you get two answers, because there are two dates. One is 25 February 2028, the compliance date for the updated "healthy" nutrient content claim. The other is 1 January 2028, FDA's uniform compliance date for food labeling regulations published between 1 January 2025 and 31 December 2026 that set no compliance date of their own. Both are final. They sit less than two months apart and work in almost opposite ways, and treating them as one deadline is the most common planning error on this subject.
One applies to your label only if you choose to put a particular word on it. The other is not a requirement at all but a mechanism: it gathers up whatever labeling changes are due and drops them on one day, so a producer makes a single artwork revision instead of three. What follows separates them, says what sits on each, says what is not on a 2028 date despite being widely reported as though it were, and works backwards from both to a schedule.
Two dates, two mechanisms: the FDA food labeling compliance date 2028 in full
Here is the whole picture, with the status word that belongs to each item. The third row is there because it is the one most often reported as if it had a 2028 date.
| Date | What it is | Status | Who it applies to |
|---|---|---|---|
| 25 February 2028 | Compliance date for the updated "healthy" claim, 21 CFR 101.65(d) | FINAL rule, VOLUNTARY claim | Only products whose labeling uses "healthy" or a derivative term |
| 1 January 2028 | Uniform compliance date for labeling rules published 1 January 2025 through 31 December 2026 that set no date of their own | FINAL | Any product covered by such a rule |
| No date exists | Front-of-package "Nutrition Info" box, proposed at 90 FR 5426 on 16 January 2025 | PROPOSED | Nobody yet. No final rule as of 2 September 2026 |
Read the status column before the dates. A final rule with a compliance date is something you schedule; a proposed rule is something you monitor. The 2028 conversation goes wrong when both land in one spreadsheet column called "deadlines".
25 February 2028: the date for the updated "healthy" claim
The final rule "Food Labeling: Nutrient Content Claims; Definition of Term 'Healthy'" was published at 89 FR 106064 on 27 December 2024 and amends 21 CFR 101.65(d). Its effective date as published was 25 February 2025, which a Federal Register notice of 25 February 2025 pushed to 28 April 2025 under the regulatory freeze memo of 20 January 2025. The compliance date did not move with it. It remains 25 February 2028, three years from the original effective date.
Now the nuance that decides whether this date is yours at all. A nutrient content claim is something you choose to make, and nothing requires a food to be called healthy. What 25 February 2028 sets is the date by which any product that does bear the term must meet the new definition. It is not a date by which every label must change.
The covered terms are listed in 21 CFR 101.65(d)(3): "healthy" and the derivatives "health", "healthful", "healthfully", "healthfulness", "healthier", "healthiest", "healthily" and "healthiness", used as an implied nutrient content claim, meaning in a nutritional context on the label. If none of those words appears there, this date is not a task on your plan. If one does, there are three possible outcomes per product, and you need to know which applies well before the artwork stage.
- It already qualifies. It meets the food group equivalent minimum and the added sugars, sodium and saturated fat limits for its category. Nothing changes on the label, but you still need the records below.
- It can qualify with reformulation. Usually that means cutting added sugars or sodium, the longest lead time on this page because it needs bench work, shelf life confirmation and fresh analysis.
- It cannot qualify. The word comes off. That is the cheapest artwork change and often the most awkward commercial conversation, so decide it first, not last.
Which category a product falls into and what limits apply are set out in the tables at 101.65(d)(3), walked through product type by product type in the updated healthy claim requirements. Two points matter for scheduling. Manufacturers may use the new criteria voluntarily now, so there is no reason to wait to convert a product that already passes. And 101.65(d)(4) requires written records, such as recipes, formulations, database analyses or batch records, verifying that the food meets the food group equivalent requirements, kept for at least 2 years after the food enters interstate commerce and produced to FDA on request during an inspection. Assembling that record set has its own lead time and belongs beside the artwork, not after it.
1 January 2028: what a uniform compliance date actually is
The second date is a different kind of object, and most of the confusion comes from not knowing what the mechanism is for. FDA does not give every labeling rule its own clock. Periodically it publishes a Federal Register notice setting one uniform compliance date for a batch of labeling regulations issued over a two-year window. The current notice, published 31 December 2024, sets 1 January 2028 for food labeling regulations published between 1 January 2025 and 31 December 2026 that do not specify a date of their own.
The reason is the one your printer quotes plate charges for. Every artwork revision carries fixed costs that do not shrink with the size of the change: prepress, proofing, plates, press setup, and the write-off of leftover stock. If four small rules each arrived with its own date, a producer would pay those costs four times for changes that could have travelled together. One date means one revision and one print run.
Two consequences follow. The first is that the uniform date applies to a class of rules, not to a list of label elements. It catches any food labeling regulation published in that window that was silent about its own timing. So the question is not "what changes on 1 January 2028", which has no single answer, but "was any final rule published between 1 January 2025 and 31 December 2026 that touches my category and set no date of its own". For many producers nothing in that window affects their panel, and the date passes without an artwork revision.
The second is that a rule setting its own compliance date sits outside the mechanism. The updated "healthy" claim is the clearest case: it carries its own date of 25 February 2028, and it was published on 27 December 2024, before the window even opens. The proposed front-of-package box is outside for a different reason: it is a proposal, not a published final rule, so nothing about it can fall onto the uniform date.
What is not on a 2028 date, despite being widely said to be
- The front-of-package "Nutrition Info" box has no compliance date at all. It is PROPOSED, published at 90 FR 5426 on 16 January 2025, comments closed 15 July 2025, and no final rule existed in the Federal Register as of 2 September 2026. If finalized as proposed, it would require compliance 3 years after the final rule's effective date for businesses with $10 million or more in annual food sales and 4 years for businesses below that, so no clock has started. Projections putting those dates in early 2030 and early 2031 are arithmetic from a hypothetical late-2026 final rule, not FDA statements.
- The Nutrition Facts panel is not changing in 2028. The format people mean by "the new label" comes from the 2016 rule, FINAL and long in force: compliance was 1 January 2020 for manufacturers with $10 million or more in annual food sales and 1 January 2021 for smaller ones. If your panel still needs that work it is overdue rather than upcoming, and the 2016 Nutrition Facts changes covers what was added.
- FDA sodium reduction targets are VOLUNTARY guidance, so no compliance date exists. Phase I was finalized in October 2021 and Phase II was still draft as of September 2026. Guidance carries no deadline because it binds no one.
- The ultra-processed foods work is not a labeling rule. A joint HHS and USDA proposed definition went to OMB on 3 August 2026 and was announced on 10 August 2026, described as a definition or research tool rather than a proposed rule. There is nothing to put on a label and nothing to schedule.
- The Daily Values did not change. The 2025-2030 Dietary Guidelines for Americans, released 7 January 2026, are a guidance document. The Daily Values in 21 CFR 101.9 are unchanged, and FDA has said only that it will assess whether the "healthy" criteria need aligning with them.
- FD&C Red No. 3 is a 2027 date for food. Foods and dietary supplements must stop using it by 15 January 2027 under the order of 15 January 2025. The 18 January 2028 date that circulates alongside it applies to ingested drugs, not food.
- State dates are not FDA dates. Texas SB 25 warning labeling has a 1 January 2027 trigger and is subject to a federal preliminary injunction against enforcement as to the plaintiff trade associations and their members. A New York date-labeling law would take effect 1 July 2028 if enacted, which was unconfirmed as of this writing. Louisiana SB 57 additive disclosure sits at 31 December 2028. None of these is an FDA compliance date.
Working backwards: the artwork and compliance schedule
A compliance date is a date by which compliant product exists, not a date on which work starts. The only schedule that holds is built by starting at the date and subtracting. The lead times below are ordinary commercial ranges, not regulatory requirements: substitute your printer's and your lab's numbers, because the shape of the plan matters more than the figures.
| Stage, working backwards | What has to be finished | Typical lead time |
|---|---|---|
| The date itself | 25 February 2028, or 1 January 2028 if a uniform-date rule applies to you | Fixed |
| Inventory turn | Old label stock and finished goods have run out | One to two full stock turns |
| Print and delivery | New labels printed, delivered and released to the line | Weeks, longer for multi-plant rollouts |
| Prepress and proofing | Final files, colour proofs, plates, barcode verification | Weeks per revision round |
| Artwork revision and sign-off | Panel rebuilt, claim text set or removed, approvals recorded | Allow at least two review rounds |
| Analysis and records | Nutrient values confirmed; for a "healthy" claim, the 101.65(d)(4) records assembled | Lab turnaround plus documentation time |
| Reformulation, if needed | New formula locked, shelf life and sensory confirmed | Months, the longest item on the plan |
| Decision gate, do this first | Per product: keep the claim, reformulate to keep it, or drop the word | Start roughly a year out |
The inventory turn is the stage most often left off. The standard is that by 25 February 2028 any product bearing the term must meet the new definition, and no sell-through allowance for stock already in trade channels is stated. Plan as though there is none: size your last order of old label stock so it runs out before the date, rather than assuming a grace period you cannot point to in writing.
The decision gate matters for the same reason. Reformulation is the only stage measured in months rather than weeks, so the decision about whether to reformulate has to come first. Running it late turns a manageable artwork project into an emergency, and that logic applies to every label change, the subject of our wider guide to nutrition label compliance.
Why the uniform compliance date is an argument for batching
The operational conclusion follows from the mechanism. FDA grouped those rules onto one date precisely so producers could make one artwork change. A producer who then makes three separate changes has paid for the mechanism and taken none of the benefit.
Batching means opening the artwork once and fixing everything known at that moment: anything on the 1 January 2028 uniform date that touches your category, the "healthy" decision for every product carrying the word, any colour additive reformulation you are doing anyway such as replacing FD&C Red No. 3 before 15 January 2027, and every defect an audit of the existing panel turns up. That last one is where the value usually sits, since ingredient statement order, allergen wording and net quantity errors cost nothing extra to fix inside a revision you are already paying for. Run the audit before the artwork opens, and against the whole label. Our FDA label checklist walks the panel element by element so the list of fixes is complete before a designer touches the file.
When both dates apply to the same product there is an easy sequencing rule. They are less than two months apart and the uniform date comes first, so build to 1 January 2028 and one revision satisfies both. When the panel itself needs rebuilding as part of that revision, the nutrition label generator produces the compliant Nutrition Facts artwork from your recipe so the only thing left to settle is the claim.
Frequently asked questions
Is 25 February 2028 a deadline to change my label?
Only if your label uses "healthy" or one of the derivative terms in 21 CFR 101.65(d)(3) as an implied nutrient content claim. The claim is voluntary, so the date is the point by which a product bearing the term must meet the updated definition, not a point by which every label must be revised.
The effective date of the "healthy" rule was delayed. Did the compliance date move too?
No. The rule was published at 89 FR 106064 on 27 December 2024 with an effective date of 25 February 2025, and a Federal Register notice of 25 February 2025 delayed that to 28 April 2025 under the 20 January 2025 regulatory freeze memo. The compliance date stayed at 25 February 2028. Schedules assuming the delay pushed everything back by two months are wrong.
Can I use the new "healthy" criteria before 2028?
Yes. The rule is final and manufacturers may use the new criteria voluntarily now. If a product already meets the food group equivalent minimum and the limits for its category, there is no reason to hold the change. Converting early also spreads the artwork work across more than one budget year.
Is there a 2028 compliance date for the front-of-package box?
No. The front-of-package "Nutrition Info" box is a proposed rule, published at 90 FR 5426 on 16 January 2025, and no final rule had been published as of 2 September 2026. The proposal would set compliance at 3 years after the final rule's effective date for large businesses and 4 years for smaller ones, so no clock is running. Anything giving the box a firm 2028 date is a projection, not a requirement.
What exactly falls on the 1 January 2028 uniform compliance date?
Any food labeling regulation published between 1 January 2025 and 31 December 2026 that set no compliance date of its own. It is a class rather than a list of label elements, which is why no one can hand you a single description of what changes that day. The step to take is to check whether a final rule published in that window applies to your category.
Do I have to keep records if I use the "healthy" claim?
Yes, under 21 CFR 101.65(d)(4). You must make and keep written records, such as recipes, formulations, analyses of databases or batch records, verifying that the food meets the food group equivalent requirements, for at least 2 years after the food enters interstate commerce, available to FDA on request during an inspection. This does not apply where the food group equivalent content is evident from the label or where the food is an automatic qualifier under 101.65(d)(3)(i).
Is the Nutrition Facts panel format changing in 2028?
No. The current format comes from the 2016 final rule, mandatory since 1 January 2020 for manufacturers with $10 million or more in annual food sales and 1 January 2021 for those below that. Nothing in 21 CFR 101.9 changes on either 2028 date.
