Since the passage of the Color Additive Labeling Act amendments in 2021, the processed food industry in the United States has found itself adjusting to a regulatory landscape that is, at once, both familiar and markedly more demanding. The core objective of the revised act—requiring explicit labeling of certain artificial colors known to trigger allergic or hyperactive responses—has been largely welcomed by consumer advocates. Yet, for manufacturers, particularly those operating at scale, the operational implications have proven to be anything but trivial.
Consider, for a moment, the typical ingredient sourcing process for a mid-sized snack producer. Color additives might appear far down the bill of materials, often nested within compound ingredients supplied by third parties. The 2021 amendments essentially forced manufacturers to unpick these complex relationships, tracing artificial colorants back to their origin to ensure that labels accurately reflect their presence. It sounds straightforward, but in practice, it has exposed a surprising degree of opacity in ingredient supply chains—something many firms are now addressing with a mix of technology, revised supplier contracts, and, it must be said, a degree of trial and error.
One of the more promising tools at manufacturers’ disposal is the FDA’s open color registry. This public database lists approved synthetic color additives, their chemical compositions, and certification statuses. By integrating this registry into ingredient traceability systems—whether bespoke or as modules within larger ERP suites—manufacturers can begin to cross-reference supplier-provided data with official records. The mechanics of this integration vary. Some firms are building direct API connections, automating the verification process. Others are adopting simpler approaches, using the registry as a reference for manual checks during supplier onboarding or when qualifying new ingredients.
But technology alone doesn’t solve the problem. It’s worth pausing to reflect on the human and procedural shifts required. Procurement teams are, increasingly, tasked with gathering detailed additive disclosures from suppliers—a task that, in earlier years, might have been considered outside their remit. And these disclosures need to be maintained in real time. After all, ingredient formulations can change. A vendor’s trusted compound mix might, without much notice, switch to a cheaper colorant, triggering the need for a label update. Manufacturers, to their credit, are responding with tighter contract terms, requiring advance notification of formulation changes. Yet enforcement remains patchy, particularly when dealing with international suppliers unfamiliar with the nuances of US labeling law.
Updating packaging lines has, predictably, emerged as another area of operational complexity. The step-by-step process here is deceptively mundane. First, firms must audit their existing packaging inventory—identifying where labels will require changes and, crucially, ensuring that outdated materials are phased out promptly. This can be tricky when dealing with long shelf-life goods or products manufactured across multiple sites. Next comes the coordination with design teams, regulatory affairs, and print vendors to produce compliant labels. The timing is tight; firms that delay updates risk running afoul of FDA enforcement. And while the FDA has, in several instances, signaled a willingness to provide transition periods, that leniency shouldn’t be assumed.
In parallel, food manufacturers are rethinking how they update public allergen and additive databases. Consumers increasingly rely on digital tools—apps, retailer websites, or direct manufacturer portals—to make informed choices about the foods they consume. This means that label updates alone are insufficient. Firms must ensure that these databases reflect the latest formulations and additive profiles. Here again, the process typically involves extracting data from the traceability system, validating it against internal formulations, and pushing updates through digital channels. A few companies have gone further, offering APIs that allow retailers or app developers to pull additive data directly, reducing the lag between formulation change and consumer notification.
What’s perhaps most striking in observing this transition is the unevenness of industry response. Large, multinational food producers generally have the resources—and internal expertise—to adapt swiftly. For them, compliance is often an exercise in scaling up existing traceability frameworks and refining processes already honed through years of managing global food safety standards. Smaller firms, by contrast, may struggle. Without dedicated regulatory affairs staff or sophisticated ERP systems, they often rely on ad hoc processes, external consultants, or industry associations to navigate the new requirements. And that reliance brings its own risks, including inconsistent data quality or delayed compliance.
There are, of course, broader policy questions at play. The 2021 amendments reflect a genuine effort to enhance transparency and protect consumers. But they also illustrate the friction that arises when regulatory intent meets supply-chain reality. Labeling artificial colors accurately sounds like a small ask. Yet behind each label is a complex choreography of supply agreements, data systems, packaging logistics, and consumer communications. Whether the system, as it evolves, will consistently deliver on the promise of transparency remains to be seen.