RFK Jr held a press conference yesterday to celebrate “the biggest news in food reform in modern history”—requiring food manufacturers to notify the FDA when they are introducing a new food additive they want considered Generally Recognized as Safe (GRAS).

This wasn’t already required?  No, it was not.  This gap is the long-troubling “GRAS loophole.”

Here’s what the press release says (my emphasis):

The FDA issued a proposed rule that would require manufacturers to notify the agency whenever they conclude that the use of a substance added to human or animal food is Generally Recognized as Safe (GRAS). The proposal would modernize the GRAS framework, increase transparency, and give the FDA greater visibility into substances entering the food supply.

Since Congress established the GRAS exemption in 1958, manufacturers have been permitted to reach their own conclusions that certain substances are generally recognized as safe under the conditions of their intended use.

Although the FDA has long operated voluntary notification programs, companies have not been required to notify the agency when making these determinations.

The proposed rule would modernize that framework by making GRAS notifications mandatory and expanding the public-facing inventory of submitted notices, significantly improving transparency while strengthening FDA’s ability to oversee ingredients entering the food supply.

For substances already on the market based on industry self-GRAS conclusions, the proposal would establish a time-limited streamlined submission pathway that would allow manufacturers to provide FDA with information about existing uses. This enables the agency to prioritize post-market safety evaluations while minimizing unnecessary regulatory burden.

Comment 

Food advocates for years have called for making GRAS notifications mandatory.  So this move is obvious, and long-awaited.

A reporter sent me an AI transcript of the press conference, which says how this will work (again, my emphasis).

What FDA will do is review a notification within 45 days to ensure that the elements required are in there. We’ll then docket that notification satisfying the requirement. FDA will then, within 180 days, review that notification substantively. If we have issues, we may either send a no questions letter or we may send we may send a letter determining that we don’t believe that the threshold has been established. But again, this is not a pre-market notification program. Companies are not prohibited from entering the market during the tenancy of that process, and they can continue to self-GRAS. What it does is require that companies notify us whenever they are self-GRASing an ingredient, and then we’re going to make that limited information public that’s set more than the regulation in 170.275.

So what’s the big deal?  Well, it’s the first food regulation proposed by the MAHA administration, and it closes the GRAS loophole.

What it does NOT do is keep unsafe additives out of the food supply.  Companies still have plenty of leeway to put whatever they want in their products.  This is not pre-market approval.  The FDA says it has no statutory authority to require that.

So why not go for it when you have the chance?  Despite the MAHA hoopla over the announcement, as Jerry Mande puts it, all this does is continue the FDA’s non-enforcement.

Another question: Does the FDA even have the staff to review food additive submissions, given the thousands who were fired or left?

Making GRAS notifications mandatory is a good thing to do.  Will doing this Make America Healthy Again?  A little, maybe, but it will be extremely hard to prove.

The big, easy-to-demonstrate food safety problems are ultra-processed foods (the FDA says it has sent an as yet unrevealed definition to OMB), and pathogenic microbes, like Cyclospora, with upwards of 25,000m cases so far, hundreds of hospitalizations, and at least two deaths.

And no, Cyclospora is not a food industry conspiracy to keep people from eating real foods–that idea is weird and unsupported by evidence.

Indeed, the FDA says:

Finally, though not part of today’s announcement, with respect to microbiological food safety, FDA will be publishing tomorrow a final guidance document titled “Guide to Minimize Biological Hazards And ready-to-eat fresh-cut produce. This final guidance is intended to help manufacturers and processors of fresh-cut produce comply with applicable FDA requirements and 21 CFR Part 117 titles current good manufacturing practices, hazard analysis, and risk-based prevention controls for human food.

Can’t wait to see this.  Stay tuned.

Resources

• The press release
• The transcript of the call with reporters
• The Federal Register notice
• Stat News on this (I’m quoted)
• FoodNavigator report (I’m quoted)
• CNN on MAHA’s GRAS notification requirement (I’m interviewed)

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I keep saying that I can often tell who funded a study from its title, and if I know the funder I can often predict the result.  But sometimes I’m wrong.  This is one of those times.

The study:  Effects of Short-Term Broccoli Powder Supplementation on Acute Oxidative Stress and Recovery Following a Metabolically Demanding Exercise Session. Cesanelli L, Venckunas T, Minderis P, Maconyte V, Stasiulis A, Snieckus A, Mickevicius M, Mickeviciene D, Kamandulis S.  Antioxidants. 2026; 15(3):379. https://doi.org/10.3390/antiox15030379

Background/Objectives: This study aimed to evaluate the effects of short-term broccoli powder supplementation on metabolically demanding exercise performance, muscle power, and blood lactate recovery. It also investigated broccoli powder-derived sulforaphane bioavailability and its effects in attenuating exercise-induced oxidative stress.

Methods: Seventeen healthy males (age 23.8 ± 4.9 years, height 182.3 ± 6.1 cm, weight 80.0 ± 12.8 kg), in a double-blind crossover design, three weeks apart, consumed ten standard doses of either broccoli powder or spinach powder as a placebo over a period of 2 weeks. They then performed a maximal progressive cycling task with concomitant analysis of expired gas composition. Plasma malondialdehyde (MDA) level was measured before and 60 min after the completion of the task, and blood lactate and muscle power (counter-movement vertical jump (CMJ) performance) were measured before and up to 60 min after exercise.

Results: The main findings were that despite urine sulforaphane output being markedly higher following broccoli supplementation (p < 0.05), which confirms effective absorption and systemic availability of the compound, this did not influence exercise-induced changes in plasma MDA concentration, blood lactate dynamics, exercise test performance, or functional recovery measured as muscle power via CMJ performance (p > 0.05).

Conclusions: In conclusion, broccoli powder supplementation, despite efficient delivery of sulforaphane, does not seem to either acutely affect performance or modify oxidative stress and recovery from metabolically demanding exercise.

Conflicts of Interest: The authors declare no personal financial relationships, consultancies, or equity interests related to this work. The Smarter Food Company (Norwich, UK) provided partial funding (unrestricted) and supplied the glucoraphanin-rich broccoli and placebo powder used as the study supplements but had no involvement in the study design, data collection, analysis, or interpretation, manuscript writing, or decision to submit for publication.

Comment: So this was one of those studies where I saw the title and asked: “Who paid for this?”  Why would anyone care about the effects of eating broccoli or spinach powder, when nobody eats such things unless they have to?  The obvious answer: the company that sells such things or is thinking of selling them.  Hence The Smarter Food Company.  But then I expected the study to say that broccoli powder produced miracles, but it does not.  High marks to the Lithuanian authors.

I am totally for the UN’s Sustainable Development Goals (SDGs). In 2015, they set targets for the betterment of global populations, to be achieved by 2030.

The targets were ambitious from the get go, but it’s a global tragedy that so little has been achieved.  Here’s the summary.

This report is especially thoughtful, not surprising given its authors.  They would like the report cited as:

Sachs, J.D., Lafortune, G., Fuller, G., Iablonovski, G. (2026). Implementing Sustainable Development: 2030 and Beyond.
Sustainable Development Report 2026. Paris: SDSN, Dublin: Dublin University Press. DOI: 20.500.14765/118015

The report stresses the need for implementation.

…the SDGs constitute the most comprehensive moral and political commitment the international community has ever made – to end
extreme poverty, ensure quality education, secure good health, achieve gender equality, decarbonize energy systems, protect oceans and forests, build sustainable cities, and make peace within and among nations.

The goals are highly ambitious and will not be achieved by the target date of 2030. ..They should remain our framework past 2030 because they define the future we want and need, even if our efforts to build that future have not yet reached the breadth, scale, and speed that the world’s governments pledged in 2015.

It lists the lessons:

1. Peace is the foundation of every Goal.
2. The SDGs are about transformation, not business as usual.
3. Transformations require long-term investments.
4. Long-term investments require long-term plans.
5. The scale of action is regional and local, not only national.
6. Finance is decisive – global public goods require global finance
7. Dangerous technologies require global governance.
8. The UN must be for all – and that means on all continents.

As for what comes next?

First, anchor the agenda in peace and human rights. Stop the wars, restore the UN Charter’s dispute-resolution mechanisms and redirect a meaningful share of military expenditure toward human development.

If only.

I’m inspired by the SDGs, imperfect as they may be (I’ve written about their strengths, gaps, and progress many times).  And I very much believe in the value of setting unrealistic goals in public health; they define aspirations, and set advocacy agendas, and sometimes they can even be achieved.

I want everyone to advocate for this report’s what comes next.

• Peace
• Human rights
• Some military spending redirected to human development

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Most people who eat enough calories get more than enough of the protein they need, so the current protein craze—putting pea, whey, and tofu into everything—doesn’t make a whole lot of sense.

It does sell products though.

It’s hard to choose from among the most entertaining protein-supplemented products.

• Coffee?
• Protein water?
• Pop-Tarts?

But this remains my current favorite.

We can—and should—ask: How Sound Is Broad Advice to Simply “Eat More Protein?”

Protein has become the centerpiece of popular nutrition advice. Grocery store shelves are lined with protein-enhanced everything. Social media influencers urge us to squeeze more protein into every meal. And now the U.S. Department of Health and Human Services is offering broad advice: simply eat more protein.

And look at the effects of this trend:

America’s Protein Boom Is Outgrowing Its Supply: Demand for whey is soaring as more Americans seek out high-protein foods and GLP-1 medications reshape eating habits. Why can’t manufacturers simply make more?

And the USDA says Animal protein continues to be plentiful for U.S. consumers.

They don’t include dairy on this chart and I have not seen a similar one for plant proteins, but plenty of those are available too.

I wish everyone would stop worrying about protein.  It’s not a nutritional issue; it’s a marketing issue.

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RFK Jr’s Make America Healthy Again (MAHA) made many promises, most of them still in the works.  But one seems to be well on the way to being achieved.  Under MAHA pressure, some companies agreed to voluntarily remove petroleum-based food colors by the end of 2027.

I went to the Target in Ithaca, NY last week and could not find a single kids’ cereal containing the dyes Red 40, Yellow 5 and 6, and Blue 1.

Target promised not to sell cereals with those dyes.  It has kept that promise.

But the Ithaca Tops still carries Froot Loops and other brightly colored, artificially dyed kids’ cereals.  Maybe they will be gone by the end of 2027?

This is a voluntary initiative.  No regulation is involved, to the great dismay of advocates.

The shift to vegetable-based dyes

• Nestlé USA removes artificial colors in all food and beverages:  The Nesquik maker joined other food manufacturers last year in pledging to eliminate synthetic dyes from the rest of its portfolio following pressure from the Trump administration.
• General Mills launches Trix, Lucky Charms cereals with natural colors: The Cotton Candy and “Moana” varieties will debut this summer, the same time the food giant expects to remove synthetic dyes across its cereals.

How is it going?

• How the shift away from artificial dyes is impacting food sales: Sales of products with natural colors grew more than those using synthetic dyes, a report from the National Confectioners Association and RTI International found.
• One Year Later: Are Synthetic Dyes Still in Our Food? Despite growing consumer concern and awareness of synthetic dyes, the Food and Drug Administration has not taken action to ban them in full. Instead, last year, the FDA called on food manufacturers to voluntarily phase them out of their products. While a number of companies have made significant commitments toward that end, others have committed to much more limited changes.
• Kennedy touts food dye crackdown as a midterm win, but big holdouts remain: Health and Human Services Secretary Robert F. Kennedy Jr. announced plans to phase out all artificial dyes from the food supply by the end of 2026. Roughly half of the major food companies have agreed to do so, though only four are meeting that deadline.

Why vegetable colors are a challenge for makers of ultra-processed foods

• Natural Colour Industry Prepares for Major Shift: The global colour industry is bracing for an unprecedented period of growth in natural colour demand due to widespread U.S. market conversion from synthetic dyes. Sensient is making major investments to secure supply and production capacity… Learn more
• Mars’ artificial-dye-free push hits major reformulation hurdles: Mars to introduce artificial-colour-free M&M’s but reformulation challenges leave two colours out in the cold… Read more
• Why food scientists still can’t crack the perfect natural red: Creating a heat-stable natural red remains one of food science’s toughest colour challenges… Read more

Comment

Advocacy groups like CSPI have for years called for removal of these dyes.  Since they are long gone from Europe, Australia, and other countries, you would think they would be easy to replace.

The problem?  Kids (and adults) think cereals and candy taste better when they are brightly colored.  Vegetable dyes are not vivid enough.

When General Mills took the dyes out of Trix some years ago, sales went down.  General Mills reinstated the dyes.

RFK Jr has explicitly stated that he opposes regulation (“nanny state”).  Hence, voluntary.

If companies can remove the dyes voluntarily, they can also volunteer to put them back.

This is a lost opportunity.

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States have reported upwards of 20,000 cases of Cyclospora-caused explosive diarrhea, some of them–but by no means all—traced to lettuce grown by Taylor Farms in Mexico and shipped to Taco Bell and, apparently, lots of other places.

The best way to keep track of all this—and it is a lot to keep track of—is to read food poisoning lawyer Bill Marler’s blog and Phyllis Entis (the bug lady) at e-FoodAlert.

I wrote about the system-failure issues raised by this Cyclospora outbreak last week.

This week, I want to talk about what to do about it.

I hate to say it, but for starters, do not eat bagged salads until this industry can get its act together and prevent human (for Cyclospora) and animal (for E. coli and Salmonella) waste from getting anywhere near irrigation water used for growing lettuce.

And maybe don’t eat lettuce at all.  You can buy whole heads, remove the outer leaves, wash what’s left, and hope for the best, but if Cyclospora is on that lettuce, it won’t wash off and is still risky.

We need to get the FDA and CDC back on the job to get producers to produce lettuce safely.  For this, I defer once again to Bill Marler.

Here is what they should have done and still could do today:

1.     Restore required Cyclospora reporting in FoodNet…FoodNet measures trends, it does not detect outbreaks. But it was narrowed eleven months before the largest Cyclospora outbreak this country has ever recorded, reinstating it costs almost nothing, and every letter Congress has sent asks for it.

2.    Make cyclosporiasis reportable in every state, not merely nationally notifiable. Those are two different things: notifiable means CDC asks for the case, reportable means state law requires it. The parasite does not observe the difference, and neither should the count.

3.    Publish one national number and update it. CDC currently maintains an outbreak page frozen at 1,947 since July 24 and a surveillance page reading 6,707, while the states themselves report 20,927. Pick a figure, define exactly what it counts, include probable cases, and refresh it on a schedule the public can rely on. An agency that will not publish the size of a problem cannot expect to be believed about the solution.

4.    Grant the citizen petition that has been sitting at FDA since Feb. 4. Stop Foodborne Illness asked the agency to adopt a policy of naming every company associated with a foodborne illness outbreak, recall or no recall. It requires no rulemaking; the Commissioner could grant it this week with a memorandum….

5.     Bring back the Microbiological Data Program, and this time give it a parasite target. The MDP was created under President Bush’s 2001 Food Safety Initiative and tested about fifteen thousand produce samples a year — bagged lettuce and spinach, cilantro, hot peppers, tomatoes, sprouts, melons — for roughly $4.5 million a year, and it accounted for something like eighty percent of all federal produce pathogen testing until it was zeroed out and shut down in December 2012….while we are at it add the parasite to CDC’s national wastewater surveillance network, which reaches roughly fifteen hundred sites and about half the country and does not look for this organism at all.

6.    Put the FSMA 204 traceability rule back on its original schedule instead of 2028. Susan Mayne, who has actually run lettuce tracebacks, said on national television this week that it would have been enormously helpful here, and that without it the same thing happens again next summer.

7.     Name Cyclospora in the pre-harvest agricultural water rule. The only numeric microbial criterion in Subpart E is generic E. coli, and FDA’s own guidance says fecal-indicator testing will not identify this parasite….

8.    Stand up the independent board Frank Yiannas has been asking for since 2025 — an NTSB for foodborne outbreaks, investigating across agency lines, publishing root cause and lessons, with no stake in the reputation of the agency whose work it is reviewing….the point is not to find fault; it is to find facts….

The point here is that our food supply needs to be a whole lot safer.  When food safety rules are in place, followed, and inspected to make sure they are followed, food poisoning incidents go down.

We saw that with meat safety in the 1990s.

Leafy greens have been a food safety problem for a long time.  It’s way past time to get that problem addressed.

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The Examination has released an investigative report in its new “Behind the Buzz” series: “Is it safe to drink Red Bull and vodka? Dubious research tied to the company has shaped energy drink policy. The company paid scientists whose studies largely found that mixing energy drinks and alcohol isn’t harmful, contrary to most research.”

The studies backed by Red Bull have been nearly unanimous in their message: Consuming energy drinks and alcohol together is no more harmful than drinking alcohol alone.

That stands in stark contrast to the vast majority of independent studies on the subject.

The Examination gathered more than 100 studies about the health or behavioral risks of mixing energy drinks and alcohol. Of the studies that received funding by Red Bull or were conducted by researchers who disclosed financial conflicts of interest with the company, 95% concluded that mixing alcohol with energy drinks did not increase those risks. Roughly 80% of independent studies reached the opposite conclusion, The Examination found.

…Laura Schmidt, a professor at the University of California, San Francisco who has examined research funded by the food and beverage industry, described those studies as “marketing dressed up as science.”

Indeed.  This is a classic “funding effect” study.  “Funding effect” is the term coined by the late (and much missed) Sheldon Krimsky to describe how industry-funded studies tend to produce results favorable to the funder’s interest, as has been frequently observed in studies funded by the pharmaceutical, chemical, and cigarette industries.

As for the funding effect in studies of food and health, see my book Unsavory Truth: How Food Companies Skew the Science of What We Eat( Basic Books, 2018)

The Examination’s investigation is particularly valuable because lives are at stake, especially for young men, the core customer for Red Bull.  Highly caffeinated energy drinks magnify the effects of alcohol.  Red Bull is often consumed with alcohol and its marketing does not discourage that combination.

Red Bull is a sugary beverage—One 8.4 ounce can contains 26 grams of sugar and 80 mg caffeine; it provides 110 sugary calories.

Red Bull ingredients: carbonated water, sugar, glucose, citric acid, taurine, natural and artificial flavors, sodium bicarbonate (baking soda), magnesium carbonate, colors, caffeine, and a few vitamins and minerals.

This is basically sugar water with a few electrolytes and taurine added.  The energy boost comes from sugar and caffeine.

The Examination authors describe their methods for identifying studies funded by Red Bull; they used AI.

I wish they had included the raw data—a list of the studies, funders, and outcomes.  As it is, we have to take them at their word, but their conclusion is certainly plausible and consistent with much other published research.

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One Year Later: How H.R. 1’s SNAP Policy Changes Are Reverberating Across the Food System

CSPI ad GFI frame this report in an interesting way, as a tale of two distinct, and sometimes at cross-purposes, Trump administration food agendas.

The first, reflected in Project 2025 and H.R. 1, represents an economic agenda focused on reducing federal spending on food assistance, shifting costs to states, and tightening eligibility so fewer people can access programs.

The second, embodied in the Presidentially-appointed Make America Healthy Again (MAHA) Commission’s assessment report and strategy, is a nutrition and public health agenda: reducing chronic disease by limiting ultra-processed foods in federal programs, promoting whole foods, and emphasizing personal responsibility in dietary choices.

These two strands sit in significant tension with one another.

Do they ever!

In just the first 8 months, 4 million people lost SNAP benefits. More than 750,000 children no longer have access. And we don’t yet know the toll that SNAP and Medicaid losses will have on WIC and free school meal participation stemming from loss of automatic eligibility conferred through SNAP and Medicaid.

That was the intent of the law, no?

And here’s what Senator Elizabeth Warren says:

Impact on grocery stores

SNAP recipients account for an estimated 8% of grocery sales.  Fewer SNAP recipients means less income for grocery stores, especially those in low-income neighborhoods.

Estimated losses due to declining enrollments are about $10 billion.

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