IN Brief:
- FDA is tracking voluntary commitments concerning six certified colours widely used across the US food supply.
- Nestlé USA, Target, Sam’s Club, and several individual product programmes are recorded as complete, while many larger portfolio changes remain in progress.
- End-of-2026 and end-of-2027 deadlines are concentrating reformulation, ingredient sourcing, factory trials, and packaging changes across multiple categories.
The US Food and Drug Administration is tracking a rapidly expanding series of food-industry commitments to remove certified synthetic colours, exposing how much reformulation remains to be completed across major manufacturers, retailers, and product categories before deadlines clustered around 2026 and 2027.
The agency’s latest tracker covers six certified colour additives frequently used in the US food supply: FD&C Green No. 3, Red No. 40, Yellow No. 5, Yellow No. 6, Blue No. 1, and Blue No. 2.
Companies are moving at markedly different speeds. Nestlé USA is recorded as having completed its stated removal of FD&C colours from its US food and beverage portfolio, while Target and Sam’s Club have also completed specified programmes.
Other large-scale changes remain in progress. General Mills is working towards removing certified colours from its full US retail portfolio by the end of 2027, Grupo Bimbo has set an end-of-2026 target across its portfolio, and Kellanova is targeting the end of 2027 for US retail foods.
Campbell’s is listed as no longer intending to produce affected foods and beverages with FD&C colours during the second half of its 2026 fiscal year. The products identified include Lance Crackers, V8 Splash, regional snack brands, and several biscuit and cookie ranges.
Kraft Heinz, Hershey, McCormick, Mars, J.M. Smucker, Walmart, and other manufacturers and retailers are also represented in the tracker, while category organisations have made commitments covering school bakery products and dairy foods.
The length of the list demonstrates that the manufacturing work cannot be reduced to finding one replacement colour. Certified dyes are used across products with very different compositions and processing conditions, and an alternative that performs acceptably in one category may fail in another.
Colour stability is affected by heat, acidity, oxygen, light, water activity, storage time, and interactions with other ingredients. A replacement that survives an ambient confectionery process may behave differently in a baked product, acidic drink, frozen dessert, dairy matrix, seasoning, or shelf-stable sauce.
Natural-source colours can also bring different flavour effects, dose requirements, solubility, and raw-material variability. Some depend on agricultural sources whose availability and price fluctuate more sharply than highly standardised synthetic ingredients.
Manufacturers consequently have to test the finished product rather than simply substitute one colour specification for another. Bench formulation is followed by pilot work, factory trials, shelf-life testing, sensory assessment, packaging checks, and formal approval of the new specification.
The production process itself may need adjustment. A colour with lower thermal stability may need to be added later, while oxygen-sensitive alternatives can require changes to mixing, filling, headspace control, or packaging barriers.
Those changes spread into procurement and inventory management. A company transitioning hundreds of products needs sufficient volumes of replacement ingredients, revised specifications from suppliers, new certificates and quality documentation, and a controlled plan for exhausting existing stocks of old formulations.
Packaging changes have to be synchronised with that conversion. Ingredient declarations, colour claims, front-of-pack wording, and digital product information may all need revision, and obsolete printed materials can create considerable waste if recipe and artwork changes are poorly coordinated.
School-food commitments add another layer. Several companies and trade bodies have adopted earlier transition dates for products supplied to kindergarten-to-12th-grade programmes, which can leave manufacturers deciding whether to maintain separate school and retail recipes temporarily or reformulate the wider product earlier.
Parallel formulations create additional complexity in planning, ingredient storage, production sequencing, quality control, and packaging. For plants with limited line capacity, an earlier complete conversion can sometimes be operationally simpler than running separate versions of the same product.
Retailers are also setting specifications independently of federal policy. Walmart, for example, intends to remove certified colours and more than 30 other identified ingredients from its US private-label foods by January 2027.
That combination of federal pressure, retailer requirements, school-food commitments, and individual corporate deadlines is compressing reformulation work across the ingredient supply chain. Colour suppliers are being asked to provide alternatives with acceptable stability and sensory performance while supporting manufacturers through application testing.
The technical difficulty varies considerably by shade and product. Some colours are relatively straightforward to reproduce from alternative sources, while others require combinations of ingredients or acceptance of a visibly different finished product.
The FDA tracker is useful because it distinguishes completed programmes from commitments that remain in progress. As of 11 August, many of the largest portfolio changes still sit in the latter category, despite increasingly close target dates.
The result will be a substantial volume of factory change through the remainder of 2026 and into 2027. Reformulation teams still have to convert recipes into stable industrial processes, while procurement, packaging, quality, and operations departments make sure the replacement products can be manufactured repeatedly rather than merely approved in development.
For US food manufacturing, the dye transition has already moved beyond an abstract policy debate. The outstanding work now consists of thousands of specifications, trials, packaging conversions, and supplier decisions — with the FDA tracker providing a public indication of who has finished and who still has production changes ahead.
