Which specific synthetic dyes is the FDA targeting for removal?

According to the FDA, the six petroleum-based certified color additives targeted for phase-out are FD&C Green No. 3, Red No. 40, Yellow No. 5, Yellow No. 6, Blue No. 1, and Blue No. 2. The agency had previously revoked authorization for Red No. 3 and is separately moving to remove Orange B and Citrus Red No. 2.

What is the USMCA review deadline and why does it matter for food companies?

July 1 is the date set for a scheduled joint review by the U.S., Mexico, and Canada under the USMCA agreement. According to DLA Piper, nearly 160 food and agriculture groups argue that failing to send a clear renewal signal at this review risks disrupting sourcing, pricing, and investment across tightly integrated North American supply chains.

Is the FDA synthetic dye phase-out mandatory or voluntary?

The phase-out is voluntary. The FDA called on food manufacturers to stop using petroleum-based dyes and switch to natural alternatives, according to Consumer Reports, rather than issuing a formal ban. Some major food companies have made firm commitments, while others — including some of the largest in the country — have not made any public pledges.

FDA slows synthetic dye phase-out amid food policy shifts

The FDA has revised its timeline for phasing out petroleum-based synthetic food dyes, slowing a process it announced in April 2025 with a target end date of 2027. Separately, nearly 160 food and agriculture organizations have signed a coordinated letter urging USMCA renewal before the agreement's July 1 review deadline. Additional regulatory fronts — including a California ultra-processed food labeling bill, a bipartisan FDA import-destruction measure, and a USDA domestic fertilizer push — are compounding compliance demands across the food and agriculture sector.

Two significant regulatory shifts emerged in mid-June with direct consequences for food manufacturers, ingredient suppliers, and agricultural traders: the FDA signaled a slower path toward removing petroleum-based synthetic dyes from the U.S. food supply, and nearly 160 food and agriculture organizations united behind a letter demanding renewal of the United States-Mexico-Canada Agreement before its July 1 review deadline, according to DLA Piper.

FDA's voluntary dye removal program loses pace

On April 22, 2025, the U.S. Department of Health and Human Services and the FDA announced a national initiative to eliminate petroleum-based food dyes from the American food supply, according to the FDA. The effort targeted six certified color additives — FD&C Green No. 3, Red No. 40, Yellow No. 5, Yellow No. 6, Blue No. 1, and Blue No. 2 — with a stated goal of removing them by the end of 2027.

Parents and doctors have concerns about petroleum-based food dyes, which have no nutritional benefit. Given the epidemic we face of childhood diabetes, obesity, depression, and ADHD, it's common sense to work together to remove these chemicals as part of our broader effort to work to improve children's healthy eating patterns. — FDA Commissioner Marty Makary, MD, MPH

Despite that framing, the phase-out is voluntary — the FDA called on manufacturers to reformulate, rather than mandating a ban, according to Consumer Reports. The FDA has since revised its removal schedule in a direction that slows the process, as DLA Piper reported on June 15, introducing fresh uncertainty for brands that had already begun ingredient pipeline and label transition planning.

Consumer appetite for action remains strong: a March 2026 nationally representative survey by Consumer Reports found that 72 percent of U.S. adults are at least somewhat concerned about synthetic dyes in food, and 66 percent say food and drug companies should be required to phase them out. The gap between public expectation and the voluntary, slowing federal program is becoming harder for brands to ignore.

Consumer Reports · © MarketScaleDownload chart

Industry commitments vary widely

A range of major food companies have made formal pledges tracked by the FDA, including General Mills, Campbell's, Conagra Brands, Danone U.S., and Grupo Bimbo, each committing to eliminate certified color additives from U.S. retail portfolios by the end of 2026 or 2027, according to the FDA's industry tracker. The Consumer Brands Association has also encouraged its members to stop manufacturing with certified color additives by December 31, 2027.

Yet significant gaps remain. Consumer Reports noted that some of the largest food companies in the country have made no commitments at all — even though several already use natural color alternatives in markets where synthetic dyes are banned or restricted.

The infrastructure is already in place, so it's just a matter of flipping the switch on the domestic side, but many of them haven't. — Brian Ronholm, director of food policy, Consumer Reports

Earlier this year the FDA revoked authorization for Red No. 3, and the agency is separately moving to remove regulations permitting Orange B and Citrus Red No. 2, according to the FDA. Those actions represent mandatory steps, in contrast to the broader voluntary program targeting the remaining six dyes.

USMCA renewal: industry draws a line at July 1

On the trade front, nearly 160 food and agriculture organizations signed a coordinated letter calling on policymakers to renew USMCA before the agreement's July 1 review date, according to DLA Piper. The breadth of the coalition — spanning both food production and agricultural interests — reflects how deeply cross-border supply chains depend on the agreement's preferential terms.

The July 1 review is a scheduled joint assessment by the three signatory governments — the United States, Mexico, and Canada — not an automatic expiration. Industry groups are nonetheless treating it as a critical inflection point, warning that failing to send a clear renewal signal risks introducing uncertainty into sourcing, pricing, and investment decisions across the food and agriculture value chain.

Additional regulatory pressure: UPF labeling, import safety, and fertilizer

California's AB 2244, which cleared the State Assembly and moved to the Senate for committee hearings, would create a state certification program allowing qualifying products to carry a "Non-Ultraprocessed Certified" label, according to DLA Piper. Large retailers with more than $10 million in annual gross sales that carry more than 25 certified items would be required to ensure that at least three such products are clearly identifiable to consumers.

At the federal level, the House Energy and Commerce Committee advanced HR 2715 — the Destruction of Hazardous Imports Act — with a unanimous 43-to-0 bipartisan vote, according to DLA Piper. The bill would authorize the FDA to destroy imported foods that fail safety inspections, closing a gap that currently allows rejected goods to be re-routed through different ports of entry; because 94 percent of all seafood consumed in the U.S. is imported, the legislation has particular significance for the seafood supply chain.

Separately, USDA Secretary Brooke Rollins announced steps to expand domestic fertilizer production by approximately 4.5 million tons per year, targeting support for roughly 400,000 producers and 290 million acres of farmland, according to DLA Piper. The initiative includes fast-tracking permits for the $4 billion Blue Point low-carbon ammonia plant in Louisiana and restarting projects originally funded through the 2022 Fertilizer Production Expansion Program, with fertilizer prices expected to remain elevated through at least 2027.

Taken together, the converging pressures — a decelerating dye phase-out, a trade agreement at a decision point, new labeling requirements, stricter import controls, and volatile input costs — demand that food and agriculture companies maintain close, real-time coordination across regulatory, legal, supply chain, and product development functions.