NFDA allows more flexibility for “No Artificial Colors” claims — with conditions.
The U.S. Food and Drug Administration (FDA) has announced a new enforcement approach that changes how food manufacturers can use “no artificial colors” and similar label claims. The update gives industry more flexibility — but also raises important compliance and documentation questions for companies that manufacture, source, or import food products into the U.S.
Below is what the change means in practical terms — and what companies should be asking now.
Why did FDA change its policy on artificial food dyes?
FDA changed its approach because its longstanding interpretation of “artificial color” treated all added colors — including those from natural sources — the same as synthetic dyes. This meant products could not claim “no artificial colors” if any color additive was used, even if it came from plants, algae, or minerals.
FDA determined this approach no longer aligned with consumer understanding and discouraged companies from reformulating away from petroleum-based synthetic dyes.
What is FDA’s new rule on “No Artificial Colors” food labels?
FDA is now exercising enforcement discretion for voluntary label claims such as:
- “No Artificial Colors”
- “No Artificial Colorings”
- “No Added Artificial Colors”
Under this approach, products may use these claims even if they contain naturally derived color additives, provided they do not contain petroleum-based synthetic dyes and the claims are truthful and not misleading.
This is a policy shift in enforcement — not a formal regulatory amendment.
Can foods with natural dyes say “No Artificial Colors”?
Yes. Under FDA’s updated enforcement posture, foods containing naturally derived color additives may use “no artificial colors” claims, as long as synthetic petroleum-based dyes are not present and the labeling is accurate in context.
However, companies must still be able to substantiate the claim with formulation and sourcing documentation.
What counts as an artificial color under FDA labeling expectations now?
FDA has not changed the underlying regulatory definitions for color additives. However, for purposes of enforcement discretion related to label claims, the distinction now focuses on:
- Petroleum-based synthetic dyes (treated as artificial for claim purposes), and
- Naturally derived colors (which may be compatible with “no artificial colors” claims)
Companies should rely on supplier technical documentation, not marketing descriptions, when making this determination.
Does this FDA policy ban synthetic food dyes?
No. FDA’s announcement does not prohibit or ban synthetic food dyes. Certified synthetic color additives remain permitted where otherwise authorized.
The change only affects how FDA intends to evaluate certain voluntary labeling claims when synthetic dyes are removed from a formulation.
Why is FDA encouraging a shift away from synthetic food dyes?
FDA has signaled a broader interest in supporting the transition away from petroleum-derived dyes by:
- Clarifying labeling flexibility
- Expanding approvals and uses for certain natural color additives
- Reducing regulatory barriers to reformulation
The updated approach is intended to support transparency and innovation — not mandate reformulation.
How does this change affect imported food products?
Imported foods are not exempt from FDA labeling expectations. Importers should confirm that:
- Product formulations match label claims
- Color additives are accurately disclosed
- Natural vs. synthetic color sources are clearly documented
- U.S. labeling reflects current formulations
For private label and co-manufactured products, the importer of record and brand owner remain responsible for label accuracy at entry.
What should importers be asking suppliers about food color additives?
Importers should be asking detailed, compliance-focused questions, including:
- Are any color additives used, and what are their exact names?
- Are the colors synthetic or naturally derived?
- What is the source of each color additive?
- Can you provide technical specification sheets and regulatory status?
- Has the formulation changed recently to remove synthetic dyes?
- Are “No Artificial Colors” claims being used on U.S. packaging or marketing?
- Is documentation available to support the claim if FDA requests it?
Generic ingredient descriptions are not sufficient to support label claims.
Will this FDA change lead to more label reviews or reformulation projects?
Yes. Many companies are already reassessing formulations and packaging. This shift is expected to drive:
- Reformulation away from synthetic dyes
- Increased use of natural pigments
- Updated front-of-pack labeling claims
- Expanded supplier documentation requests
- More internal regulatory and quality reviews
What should companies do now to reduce compliance risk?
Food companies and importers should:
- Review formulations that include any color additives
- Confirm color source documentation from suppliers
- Reevaluate existing and planned label claims
- Align regulatory, quality, and marketing teams
- Maintain clear substantiation files for FDA review
Bottom Line
FDA’s new approach creates labeling flexibility — not a free pass. Companies that use or plan to use “No Artificial Colors” claims should ensure their formulations, supplier records, and documentation fully support the claim.
As enforcement visibility increases, clear sourcing and substantiation will matter more than ever.
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