The Road to Reformulation

The FDA wants to remove petroleum-based synthetic dyes from food and beverages by the end of 2026, replacing them with natural alternatives. This directive, which is a voluntary program and not a ban, mirrors recent state-level legislative actions that center around a small percentage of the population who may be impacted by some synthetic dyes in high quantities. While on the surface, the move to replace artificial food dyes with natural dyes may seem straightforward, there are numerous reformulation challenges.

With the FDA’s requested transition date by the end of 2026, the countdown has now started with only 19 months for products to be identified, assessed, reformulated, and commercialized. Reformulating each product will have its own unique challenges. For example, the general rule is the more vibrant and brighter the color, the more difficult it will be to substitute.

Here are six key considerations when planning a reformulation:

1. pH Sensitivity: Many naturally derived color additives have specific pH ranges that they work best in (i.e., in a more acidic product, many color additives would be redder while in a more neutral product, the same colors will become more purple).
2. Shelf Life: Because naturally derived color additives have shorter shelf lives than synthetic alternatives, higher concentrations may be required to approximate the desired product shelf life. It is likely that some products will see a decrease in shelf life overall as the shelf life becomes dependent on the visual acceptability of the product. In color systems where multiple colors are used together, additional shelf-life considerations are needed as each color will change at different rates.
3. Environmental Sensitivity: Some naturally derived color additives are heat, light, moisture, or oxygen sensitive, degrading quickly in an environment where these are present. This might make some naturally derived color additives unsuitable for some applications or necessitate a packaging change.
4. Vibrancy: Naturally derived color additives tend to be less vibrant than synthetics so bright colors may be harder to replicate and fade more quickly.
5. Availability: As many companies reformulate multiple products at once, the demand for naturally derived color additives is expected to outpace supply, leading to shortages until production capacity increases.
6. Cost: Naturally derived color additives will be more expensive when substituting for synthetic colors.

Learn More at IFT FIRST

From consumer expectation to product properties and price, the road to reformulation is going to be a bumpy one as companies adapt to meet the FDA’s aggressive timeline. An important stop on the road to reformulation will be IFT FIRST this summer where the food science community will gather to address the future of food additives and artificial food dyes, among other important topics. The three-day event will identify data-driven approaches to accelerate food formulation development as well as provide an in-depth examination of food additives reformulation and regulatory challenges, courtesy of a panel of top food industry leaders. Product developers seeking reformulation help beyond educational sessions will find a variety of solutions on the expo floor, which will include the unveiling of revolutionary new product development tool that will ease the burden of the 19-month deadline from the FDA.

Related Resources

• How Safe Are Food Dyes? An Expert Weighs in on the Research & Regulations: Hear more from IFT's Renee Leber in this Sound Bites podcast episode.
• EP 53: Red-Hot Food Dye Substitutes: IFT’s Renee Leber delves into food color additive bans, why color reformulations can be challenging, and what manufacturers need to keep top of mind when adjusting colors in various applications.
• What’s Red-Hot in Food Dye Substitutes? In this Food Technology article, IFT's Renee Leber explores the history and current state of synthetic color and food dye regulations in the United States and suggests the top considerations for product developers when reformulating food and beverage products.
• Reimaging Reformulation: What Could Go Wrong? In this Food Technology article, IFT's Renee Leber details what to consider when embarking on a product reformulation process, including prework planning, consumer demand, and costs, and how to minimize or troubleshoot inevitable bumps in the road.
• California Artificial Color Ban: Science or Sentiment? The need for science and FDA oversight, and not perception, to guide regulation was a key takeaway from a discussion among panelists during an IFT webinar on artificial colors.
• Natural Selections: Clean Label Colors Edge Out Synthetics: In this Food Technology ingredients column, the author explores the history of food colors, the size and growth of the natural food colors market, and some of the new natural colors.
• True Colors: A visually oriented overview of food color and colorant ingredient trends.
• Food Additives Overview and Toolkit: Elevate your understanding of food additives. Gain clarity on regulatory statuses, delve into scientific studies, explore viable alternatives, and expand your knowledge with curated additional reading. The overview covers 17 food additives including artificial colors, whitening agents, preservatives, oils, and indirect additives used for packaging.