FDA Releases Human Foods Program (HFP) 2026 Priority Deliverables

The U.S. Food and Drug Administration (FDA) Human Foods Program (HFP) published its 2026 Priority Deliverables, outlining a broad agenda under the Trump administration’s Make America Healthy Again (MAHA) strategy to advance food chemical safety, nutrition, and microbiological risk oversight.

The FDA Human Foods Program, created in 2024, sets and executes FDA’s food regulatory priorities. The recently released Priority Deliverables provide insights into the agency’s regulatory direction for the year ahead, including anticipated guidance and rulemaking, and areas of heightened enforcement and compliance focus for food manufacturers, retailers, and other stakeholders.

Food Chemical Safety

• GRAS Reform: FDA plans to publish a proposed rule to mandate submission of Generally Recognized as Safe (GRAS) notices for human and animal food substances, effectively eliminating the longstanding ability to market ingredients based solely on self-GRAS determinations. (See MoFo’s GRAS Client Alert.) A shift from FDA’s longstanding voluntary GRAS framework to mandatory notification would materially alter the regulatory landscape and invite scrutiny of the agency’s statutory authority and policy basis for advancing a mandatory GRAS notice regime.
  
  Companies should begin assessing the impact of a potential mandatory GRAS notice regime by reviewing existing GRAS positions, evaluating confidentiality and trade secret implications, considering supplier documentation needs, and preparing internal processes in the event that submission of GRAS notices are required.
• Post-Market Chemical Oversight: FDA plans to continue reassessing chemicals used in food, prioritizing substances identified by the agency as ones of higher concern to consumers (including phthalates, propylparaben, butylated hydroxyanisole (BHA), and butylated hydroxytoluene (BHT). FDA also plans to publish the first edition of its Systematic Post-Market Assessment process, which will include how substances are selected and evaluated, opportunities for public participation, and decision-making criteria.  
  
  Currently, FDA maintains a public inventory of certain food ingredients that the agency has determined are unsafe because they are unapproved food additives that are not GRAS when used as intended, as well as a list of select chemicals in the food supply—including food ingredients, food contact substances, and contaminants (like short-chain PFAS, phthalates, and heavy metals)—under agency review.

• Expanded Chemical Safety Action: FDA plans to expand research into contaminants and chemicals in the food supply, including heavy metals, PFAS, microplastics, and color additives. FDA also plans to establish action levels for cadmium and inorganic arsenic under the agency’s Closer to Zero initiative, accelerate review of natural color additives to support the phase-out of petroleum-based dyes, issue final guidance on new dietary ingredient notifications for dietary supplements, and promote best practices related to caffeine and allergen labeling.

Nutrition

• Ultra-Processed Foods Research: This year, FDA plans to continue collaborating with USDA and other federal partners on gathering information, data, and research. FDA will also analyze comments submitted in response to its 2025 Request for Information, as part of an effort to develop a federal government definition of ultra-processed foods. (See MoFo’s UPF RFI Client Alert.)
• Infant Formula Safety: FDA plans to modernize infant formula nutrient requirements based on “scientific evidence, expert input, and extensive public recommendations received” through Operation Stork Speed initiatives. Importantly, the agency plans to release exposure data on a range of heavy metals and other contaminants, namely, lead, arsenic, cadmium, mercury, and PFAS.
• Nutrition Transparency: FDA plans to complete its review of public comments received in connection with the agency’s front-of-package nutrition labeling proposed rule and take steps to advance to the final rule stage. The agency additionally plans to assess whether the label term “healthy” should be updated to align with the newly released Dietary Guidelines (see MoFo’s Dietary Guidelines Client Alert) and to reform outdated food standards of identity, building on the agency’s actions last year to revoke 52 now-obsolete food standards of identity. (See MoFo’s Standards of Identity (SOI) Client Alert.)
• Food Labeling for Online Grocery Platforms: FDA noted that, as online grocery shopping has grown more popular, certain required food label information may not always be readily accessible to consumers in digital retail environments. In 2026, FDA plans to issue draft guidance addressing food labeling for online grocery shopping, including the online presentation of Nutrition Facts, ingredients, and allergen information. This follows FDA’s April 2023 RFI to learn more about food labeling information provided on online grocery shopping platforms. The agency’s stated goal at that time was to obtain current information on the content, format, and accuracy of food label information presented on online grocery platforms to help improve customer access to consistent and accurate nutrition, ingredient, and allergen information for packaged foods sold through e-commerce.

Microbiological Food Safety

• Inspection and Oversight Modernization: FDA plans to modernize inspection and oversight systems by expanding reliance on state partners for routine inspections and strengthening the Integrated Food Safety System through training and coordination. This will allow FDA to focus resources on higher risk and more complex oversight activities.
• Food Traceability Rule: FDA intends to facilitate stakeholder education opportunities before the compliance date (July 20, 2028) of the Food Traceability Rule.
• Food Safety Tools and Outreach: Additional priorities include expanded training and outreach related to produce, dairy, and egg safety; updates to the FDA Food Code and Retail Program Standards; and efforts to improve recall speed, classification, and communications. FDA also plans to take advantage of tech advancements such as AI-predictive models based on food supply chain datasets—across growth, harvest, transportation, manufacturing, and distribution—to support more predictive and risk-based food safety oversight.

If you have questions about how these evolving FDA priorities may impact your business or product portfolios, please contact MoFo’s FDA + Healthcare Regulatory and Food + Agriculture teams.