FDA Issues 2026 Priority Deliverables for the Human Foods Program

The Food and Drug Administration's (FDA's) Human Foods Program (HFP) recently released a document explaining its 2026 Priority Deliverables.¹ Concurrently, the agency published its 2026 guidance agenda.² The Priority Deliverables and guidance agenda reflect what FDA plans to accomplish in 2026. The announcement states that the HFP plays a critical role in implementing the Trump Administration's Make America Healthy Again agenda. FDA plans to provide updates on the 2026 Priority Deliverables as it makes progress throughout the year. In addition to summarizing the agency's priorities for 2026 below, we also provide the recently released list of guidance under development.

HFP’s 2026 Priority Deliverables

The Priority Deliverables are grouped into three subject areas: 1) Food Chemical Safety; 2) Nutrition; and 3) Microbiological Food Safety. Items with headings in italics also appeared on the HFP 2025 Priority Deliverables List.

Food Chemical Safety

The 2026 Priority Deliverables placed chemical safety initiatives at the top of the list. FDA’s initiatives include the following:

• GRAS Reform: FDA will publish a proposed regulation to require the submission to FDA of Generally Recognized as Safe (GRAS) notices for all new substances claimed to be GRAS. FDA frames its 2026 plans as the “biggest update” to its food-additive oversight.
• Post-market Safety Reviews of Marketed Food Chemicals: FDA will continue reassessing chemicals used in food, beginning with safety reviews of phthalates, propylparaben, butylated hydroxyanisole (BHA), and butylated hydroxytoluene (BHT), among others. FDA will also post the first edition of the Systematic Post-Market Assessment process and will expand staffing at the HFP’s Office of Post-Market Assessment.
• Microplastics: FDA will research methods that accurately and reproducibly detect, quantify, and characterize microplastics in human food to help the agency identify contaminants and take regulatory action.
• Closer to Zero: FDA will establish action levels for cadmium and inorganic arsenic in baby and toddler foods to advance the ongoing Closer to Zero goal of reducing heavy metals in the food supply. FDA will also issue guidance on preventive controls to minimize chemical hazards in all foods, and support surveillance for chemical contaminants.
• Adoption of Natural Color Additives: FDA will publish draft guidance on when fruit- and vegetable-derived juices qualify as color additives under FDA regulations. It will also complete reviews of additional natural colors and prioritize evaluation of any new natural color submissions. The announcement states that FDA is “prioritizing a shift from petroleum-based food dyes to natural alternatives” and that it will focus on expediting review of natural colors as petroleum-based food dyes are phased out.³
• Consumer Exposure to Contaminants in Food: FDA will conduct the next Food Safety and Nutrition Survey and continue studying exposure to certain heavy metals and per- and polyfluoroalkyl substances (PFAS).
• Regulation of New Dietary Ingredients: FDA will release final industry guidance on safety and identity information required for new dietary ingredient (NDI) notifications. FDA will also develop methods for streamlining review of NDI notifications to assure compliance with the statutory 75-day review timeline given the growth of the dietary supplement industry.
• Dietary Supplement Oversight Modernization: FDA will evaluate new regulatory approaches and continue its targeted enforcement strategies for violative dietary supplement products.⁴
• Guidelines for Caffeine Labeling: FDA will highlight industry best practices for labeling added caffeine content in both packaged foods and beverages and at retail and restaurant settings.
• Allergen Labeling: FDA will offer multiple opportunities for the public and scientific community to provide input on food allergens. FDA will develop recommendations on transparency in disclosures of food allergen ingredients.

Reducing Chronic Disease Through Better Nutrition

Nutrition focused deliverables also moved up a spot in 2026 (from third to second). FDA’s priorities for 2026 include:

• Ultra-processed Foods: FDA will collaborate with USDA and other agencies to gather information and analyze comments to the 2025 Request for Information to develop a federal government definition of ultra-processed foods.
• Infant Formula Safety (Operation Stork Speed): In support of Operation Stork Speed, launched in March 2025, FDA will begin modernizing infant formula nutrient requirements based on analysis of scientific evidence and public recommendations. The agency will release exposure data on a range of heavy metals and other contaminants, including lead, arsenic, cadmium, mercury, and PFAS.
• NIH-FDA Nutrition Regulatory Science Program: FDA and the National Institutes of Health will design a research agenda and study how and why ultra-processed foods harm people’s health, how certain food additives might affect metabolic health, and the role of maternal and infant dietary exposures on subsequent health outcomes.
• Front-of-Package (FOP) Nutrition Labeling: FDA will analyze public comments on its 2025 proposal to require FOP labeling and prepare options for FDA leadership to make decisions on the content of a final regulation.
• “Healthy” Claim Implementation: In 2026, FDA will assess whether changes to the voluntary “healthy” claim rule finalized in 2025 are necessary to align with the 2025-2030 Dietary Guidelines for Americans. The agency will continue implementing the updated criteria, “including by advancing a potential guidance that identifies a symbol to depict the ‘healthy’ claim.”
• Food Standards of Identity: FDA will complete an interim final rule, two new final rules, and publish new proposed rules to continue to eliminate outdated standards of identity. The announcement states that FDA has begun the process to revoke 52 food standards of identity deemed obsolete.⁵
• Added Sugar Reduction: FDA will create a new added sugar reduction strategy to propose a nutrient content claim for added sugars (defining “low added sugar”), investigate ingredient and menu labeling requirements, assess the use of low or no-calorie and non-nutritive alternative sweeteners, and explore strategies for labeling sugar alternatives that do not increase blood glucose.
• Sodium Reduction: FDA will issue a formal evaluation of the Phase I targets, issued in 2021, for the agency’s multi-year voluntary sodium reduction initiative.
• Food Labeling for Online Grocery Shopping: FDA plans to issue new draft guidance on food labeling for online grocery shopping to increase consumer access to nutrition facts, ingredients, allergens, and other information.
• Guidelines on Direct Marketing of Certain Foods to Children: FDA and the Federal Trade Commission will explore the development of potential industry guidelines and other strategies to limit direct marketing of certain unhealthy foods to children.

Microbiological Food Safety

Notably, FDA’s microbiological safety initiatives are now the last item on FDA’s list. The agency’s 2026 initiatives include:

• Food Inspection Coverage by Leveraging State Capacity: FDA will begin creating Better Regulatory Inspections for Dynamic Government Efficiency (BRIDGE), by “relying on state partners to carry out more routine food safety systems inspections, while still maintaining FDA’s rigorous national standards.” FDA will begin a “proof of process” in 2026 with full implementation occurring over the following four years.
• National Regulatory and Laboratory Training System: FDA will establish the National Coordination Center to implement consistent training standards and accessible learning for federal and state Integrated Food Safety System (IFSS) regulatory and laboratory professionals. FDA and IFSS will establish a training system that distributes responsibility for designing and delivering training across federal agencies, state and local regulatory and laboratories, associations, academia, private training companies, and industry.
• Oversight and Safety of Imported Food: FDA will enhance import screening based on expanded data sources and quantitative analytical techniques, such as artificial intelligence and machine learning. The agency stated that it will “fully utilize” authorities such as Import Certification and Foreign Supplier Verification Programs. FDA will focus on the Food Safety Partnership with Mexico, regulatory partnership arrangements, and Systems Recognition initiatives.
• Imported Seafood Safety: FDA will complete development of a seafood fraud identification program. FDA will continue seeking additional authority from Congress to require the destruction of imported seafood and other imported FDA-regulated products that pose a significant public health risk. FDA also plans to advance Regulatory Partnership Arrangements with the leading shrimp-exporting countries (India and Ecuador), continue its emphasis on sampling for surveillance and compliance for shrimp supply chains, and establish whole genome sequencing capabilities and data sharing for the shrimp supply.
• Fresh and Processed Produce Safety: FDA will issue new cantaloupe safety guidelines and will conduct pilot projects on leafy greens data and cucumber safety. FDA will partner with Mexico on product import safety and advance additional training materials on agricultural water requirements and sprout production.
• Dairy and Egg Safety: FDA will enhance training and education for dairy and egg producers through a high-risk dairy training course for state regulators, examination of cheese aging practices, outreach to small ice cream producers and small egg producers, and a library of safety resources for queso cheese manufacturers.
• Recall Process Modernization: FDA will incorporate feedback from stakeholders to enhance public access to critical recall information and continue process improvements to recall speed and transparency.
• Food Traceability: FDA will engage quarterly with stakeholders and educate covered entities to ensure that they can comply with the Food Traceability Rule by the compliance date. FDA will facilitate a tabletop exercise with producers, processors, distributors, retailers, and technology partners to test traceability readiness and will provide Q&As for industry on implementing traceability measures.
• Food Code and Retail Program Standards: FDA will release an updated Food Code that reflects updates to retail food science, best practices, and current data on retail foodborne outbreaks. The agency will develop a companion Retail Program Standards manual to help state, local, and tribal agencies improve their food safety programs.
• Tech-enabled Advances in Risk Management: FDA will develop a plan to use AI-predictive models to analyze large datasets generated by the food supply chain across sectors, such as growth, harvest, transportation, manufacturing, and distribution. FDA will also explore the application of external third-party audit data to optimize FDA resources. The agency will conduct a proof-of-concept demonstration in 2026 to demonstrate the value of improving the accuracy of the facility inventory using publicly available data.

Foods Program Guidance for Industry Under Development

In 2026, FDA plans to publish guidance for industry as drafts or final documents on the following topics:

Food Chemical Safety, Dietary Supplements, and Innovation

• Action Levels for Cadmium in Food Intended for Babies and Young Children; Draft Guidance for Industry
• Action Levels for Inorganic Arsenic in Food Intended for Babies and Young Children; Draft Guidance for Industry
• Action Level for Opiate Alkaloids on Poppy Seeds; Draft Guidance for Industry
• Food Colors Derived from Natural Sources: Fruit Juice and Vegetable Juice as Color Additives in Food; Draft Guidance for Industry
• Hazard Analysis and Risk-Based Preventive Controls for Human Food; Chapter 12: Preventive Controls for Chemical Hazards; Draft Guidance for Industry
• New Dietary Ingredient (NDI) Notifications and Related Issues: Identity and Safety Information About the NDI; Guidance for Industry

Nutrition

• Compliance Policy Guide for Determining the Identity, Quality, and Purity of Olive Oil and Olive-Pomace Oil Products; Draft Guidance for FDA Staff
• Food Labeling for Online Grocery Shopping Platforms; Draft Guidance for Industry
• Protein Efficiency Ratio (PER) Rat Bioassay Studies to Demonstrate that a New Infant Formula Supports the Quality Factor of Sufficient Biological Quality of Protein; Guidance for Industry

Microbiological Food Safety

• Evaluation and Establishment of Safety of Low-Moisture Ready-to-Eat Foods Following Equipment Microbiological Contamination Event; Guidance for Industry
• Guide to Minimize Food Safety Hazards of Fresh-cut Produce; Guidance for Industry
• Hazard Analysis and Risk-Based Preventive Controls for Human Food: Chapter 10: Sanitation Program; Draft Guidance for Industry
• The Accredited Third-Party Certification Program: Questions and Answers; Guidance for Industry
• The Food Traceability Rule: Questions and Answers; Draft Guidance for Industry

References

1 Human Foods Program (HFP) 2026 Priority Deliverables, U.S. Food & Drug Administration, Jan. 27, 2026, https://www.fda.gov/about-fda/human-foods-program/human-foods-program-2026-priority-deliverables.

2 HFP, Foods Program Guidance Under Development, U.S. Food & Drug Administration, Jan. 23, 2026, https://www.fda.gov/food/guidance-documents-regulatory-information-topic-food-and-dietary-supplements/foods-program-guidance-under-development.

3 See HL Update, FDA Notifies Industry of Enforcement Discretion Regarding “No Artificial Colors” Claims, (Feb. 6, 2026), https://www.hoganlovells.com/en/publications/fda-notifies-industry-of-enforcement-discretion-regarding-no-artificial-colors-claims.

4 See HL Update, FDA Notifies Industry of Enforcement Discretion Regarding DSHEA Disclaimer on Dietary Supplement Labels, (Jan. 28, 2026), https://www.hoganlovells.com/en/publications/fda-notifies-industry-of-enforcement-discretion-regarding-dshea-disclaimer-on-dietary.

5 See HL Update, FDA Proposes Revoking Standards of Identity for 52 Food Products (July 18, 2025), https://www.hoganlovells.com/en/publications/fda-proposes-revoking-standards-of-identity-for-52-food-products.

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