Will 2025 be a year of radical change for nutrition labeling? The FDA isn’t an agency known for expedient action, however, with an incoming administration that’s promised to shake things up, anything is possible.

The Work Goes On

There are a number of food labeling initiatives in the pipeline that could be affected by the incoming administration. That said, the FDA has shown that they are continuing business as usual with their December 19th final ruling on the “healthy” nutrient content claim.

“Healthy” Claim Update

The FDA updated the definition for the “healthy” claim on food packaging with respect to our current understanding of nutrition. Under the previous rule a yogurt that’s high in added sugar could still qualify as “healthy” whereas salmon would be disqualified since it's high in total fat. Now, the “healthy” claim puts limits on saturated fats, sodium, and added sugars and focuses on a minimum amount of recommended food groups (vegetables, fruits, protein foods, etc.) versus a minimum amount of beneficial nutrients.

It's great to see progress continue and there are many other initiatives still in the works.

2025 FDA Initiatives In Progress

• Front-of-package (FOP) Nutrition Labeling: Over the past few years the FDA has been researching a simplified and standardized system for front-of-package nutrition. This system would provide at-a-glance nutrition information to help consumers quickly and easily make healthier food choices. We’ve seen other countries roll out front-of-package regulations like this. For example, the Canadian front-of-packaging labeling requirement introduced in 2022 calls out foods that are high in saturated fat, sugar, or sodium.
• “Healthy” Symbol: Related to the updated “healthy” claim, the FDA is looking to establish a symbol that can voluntarily be used on “healthy” products to allow consumers to easily make more informed dietary decisions.
• Standard Date Labels: Many of the FDA’s initiatives are based around a National Strategy set forth by the Biden-Harris administration to end hunger and increase healthy eating and physical activity by 2030. The FDA is evaluating standardizing date labels to combat food waste in accordance with these goals. By mandating the phrase “best if used by” for date labeling, consumer confusion over different terms (i.e. sell by, use by) could be avoided and lead to less food being thrown away prematurely.

What’s Likely To Happen

Our hypothesis is that some initiatives will be slowed down under the new administration. While we don’t see any reason to think things will be flipped upside down, if we take the administration’s word we can expect to see downsizing. With fewer people the possibilities are limited for some of the more ambitious initiatives.

A more likely place change could happen is around areas of de-regulation, which has yet to be directly called out in terms of nutrition labeling.

But what about the nutrition labeling initiatives that are already in the works?

• Front-of-package (FOP) Nutrition Labeling: We think this initiative is less likely to happen and may be slowed down due to changes in the agency. The rule would add complexity and while the rationale makes sense, being able to show measurable improved outcomes is not easy. In either case we’d expect a slow rollout of an FOP requirement. In Canada they released their FOP rules in 2022 but the rules do not become mandated until January 1, 2026.
• “Healthy” Symbol: It is promising that the final rule on the update “healthy” claim definition was established. That said, the symbol initiative is less likely to be fast tracked. As a voluntary symbol it would require less oversight than FOP, but still adds work to the agency’s plate.
• Standard Date Labels: This initiative seems to have a general consensus for support both by the FDA and industry stakeholders. It’s also fairly straightforward. Of the labeling initiatives in the pipeline we see this one as the least likely to be slowed down by the changing administration.

ReciPal’s Approach To Changing Regulation

We expect that the changing administration means that some of the labeling initiatives may be impacted and we continue to keep our finger on the pulse. The ReciPal team is composed of food labeling experts and highly skilled developers. As such, we stay up to date on all FDA news and can quickly react to any changes (even though there’s almost never anything that comes by surprise).

Just as we built out functionality for Canada’s FOP requirements, we’re ready and able to provide these features to address similar guidelines in the US. We’re also working to proactively provide features that add value to our users even before they’re mandated. Like everything at ReciPal, we try to keep things as simple as possible and automatically apply the rules so you can create compliant labels with confidence. If you have a question about staying compliant with FDA guidelines we offer consulting services to help you work through any potential issues.