2025 was the year the food industry spent bracing for change that mostly didn't arrive on schedule and quietly missing the shift that actually did.
That's roughly how Dr. David Acheson, founder and CEO of The Acheson Group, framed the year in our January FSMA Friday session. We covered a lot of ground: food dyes, ultra-processed foods (UPFs), self-affirmed GRAS, Listeria, dietary guidelines, FDA staffing cuts, and traceability. Here's what matters most heading into 2026.
Q: How would you describe 2025 for the food industry overall?
A: Dr. Acheson described it as a year of drama, headlines, and a fair amount of panic; especially in the early months when a new administration arrived with the Make America Healthy Again (MAHA) agenda and a long list of things it wanted to change. Food dyes, ultra-processed foods, GRAS reform, FDA personnel cuts — all of it hit at once, and the food industry wasn't quite sure what to make of it.
Looking back, his read is that 2025 turned out to be more of a setup year than an execution year. A lot of things got put on the table, but very few moved as fast as initially feared. Some of the noise settled. Some didn't. And a few issues, self-affirmed GRAS in particular, are still moving and deserve serious attention in 2026.
Q: What actually happened with food dyes?
A: A lot of people expected FDA to come out with a regulation banning artificial dyes. That didn't happen. Instead, FDA went to the major manufacturers that use artificial colors and essentially said: we'd like you to phase these out voluntarily. For the most part, those companies complied.
Dr. Acheson's take is that most of them already saw this coming; they just needed a push. The bigger practical issue was whether there were enough approved natural color alternatives to replace what was being removed, particularly certain blues. FDA has since approved some of those missing options, which has helped move things along.
He doesn't think a formal ban is a high priority in the near term, given how much voluntary movement has already happened. But he wouldn't rule it out. For manufacturers still using artificial dyes, the direction of travel is clear.
Q: Ultra-processed foods got a lot of attention in 2025. Where did that end up?
A: Ultra-processed foods were front and center in the MAHA conversation, and there was real concern the industry would face significant regulatory pressure. Then something predictable happened: before you can regulate ultra-processed foods, you have to define what they are, and that turned out to be a much harder problem than anyone acknowledged upfront.
Dr. Acheson compared it to FDA's decades-long struggle to define "natural" in food labeling. That battle was never resolved, and he suspects the definition fight around ultra-processed foods will take a great deal of time as well. Getting something that holds up to legal challenge at a federal regulatory level isn't a quick process.
The issue hasn't gone away; it's still a stated priority, but it's moving slowly. For QA managers, this is a "monitor it, don't restructure your programs around it" situation for now.
Q: You mentioned self-affirmed GRAS is moving faster than the others. What is it, and why does it matter right now?
A: GRAS (Generally Recognized as Safe) is the legal basis for most ingredients used in food. There are three ways an ingredient can carry that status. It can be pre-1958 and grandfathered in based on historical use. It can go through FDA's formal notification process, where a company submits scientific evidence and FDA reviews it. Or a company can self-affirm it, meaning they evaluate the science internally, decide the ingredient is safe, and never involve FDA at all.
That third pathway has been controversial for years. Dr. Acheson noted it was already a target when he was at FDA. MAHA gave it new momentum, and he believes it's genuinely vulnerable to regulatory change.
His advice was direct: go through your ingredient lists now. Find out from your suppliers whether any ingredients they provide are GRAS on the basis of self-affirmation. If a rule changes or eliminates that pathway, those ingredients could become legally off-limits quickly. You can cross-check by looking up ingredients in FDA's GRAS notification database; if an ingredient isn't listed there, the formal FDA process likely wasn't used.
This is the kind of supplier-level exposure that's easy to miss until it becomes a supply disruption. Getting visibility into what your supply chain is built on and where the vulnerabilities are, is exactly the kind of work that pays off before an enforcement action, not after.
Q: What were the key regulatory updates on Listeria and dietary guidelines?
A: On Listeria, FSIS issued guidance that was significant more for how directly it was stated than for any new science behind it. FSIS told industry: if you find Listeria species, and not just Listeria monocytogenes, in your facility environment, you need to take it seriously and pursue it aggressively. Most ready-to-eat manufacturers were already operating that way, but this is the first time FSIS made it that explicit. The message is that they're watching how companies respond to environmental findings, and a real investigative response is expected. In January 2026, FSIS reissued the guidance adding inspection personnel instruction, reaffirming its focus on the testing.
On dietary guidelines, the 2025-2030 update, issued in January 2026, was a notable departure from prior editions in length and in framing. The guidance shrank from hundreds of pages to ten, and the central message shifted to a simple idea: eat real food. Defined in the guidelines as foods that are minimally processed, recognizable as food, and free of added sugars, industrial oils, and artificial flavors and preservatives. These aren't enforcement rules. But they reflect where consumer expectations are heading and are worth tracking if you're involved in formulation or labeling decisions.
Q: There's been a lot of talk about FDA staffing cuts. What's the real-world impact?
A: Dr. Acheson has seen FDA slowdowns in some areas: import alert reviews and certain administrative processes are taking longer than they used to, which he attributes to staffing shortages. The GAO also weighed in during 2025 with a report criticizing FDA's progress on its FSMA obligations. The traceability rule was cited as one of the most significant unfinished items.
That said, he was emphatic on one point: cause-based inspections triggered by an active outbreak investigation have not slowed down. When FDA has evidence linking a product to illness, they still move fast and with full resources.
His concern is that some manufacturers might read the broader slowdown as breathing room. It isn't. On Salmonella and Listeria in ready-to-eat foods, the regulatory appetite for enforcement is as strong as ever. Whole genome sequencing keeps improving, which means the agency is only getting better at connecting contamination events back to the facilities responsible.
Q: What's the practical advice heading into 2026?
A: Don’t let the noise pull your attention from the fundamentals. The big-ticket MAHA topics get the headlines, but the leading cause of recalls continues to be undeclared allergens. At the same time, pathogen risks like Salmonella and Listeria, particularly in ready-to-eat foods, remain serious hazards that can trigger significant enforcement action. The consequences of getting it wrong haven’t changed. The probability of getting caught has gone up.
A few things worth prioritizing:
- Review your ingredient lists for self-affirmed GRAS exposure before a rule change forces the issue
- Keep Listeria and Salmonella controls sharp, especially in ready-to-eat environments where environmental monitoring matters most
- Stay engaged on traceability: the rule has been delayed, but enforcement expectations haven't gone away
- Document what you know. If institutional knowledge lives in someone's head and they leave, your programs carry that gap forward
The Takeaway
2025 set a lot of things in motion. Some moved faster than expected, GRAS reform chief among them. Others stalled in definitional debates or got deprioritized as the administration worked out what it actually wanted to do. What didn't change is the underlying expectation that food manufacturers know their risks, control them, and can show their work when someone comes knocking. That part has only gotten more serious.
Watch the full conversation here:
