In a letter issued February 5, 2026, the U.S. Food and Drug Administration (FDA) said it intends to exercise enforcement discretion when food manufacturers use voluntary “no artificial colors” labeling claims on products that do not contain FD&C certified colors.
The clarification affects how food companies substantiate labeling claims during reformulation and product updates, an area that has created uncertainty as manufacturers move away from certified synthetic dyes.
While the letter provides additional flexibility, it does not change existing legal requirements, leaving companies responsible for ensuring that ingredient approvals, labeling language, and supporting documentation remain compliant.
This article explains what the FDA’s latest letter means for you, where risks still exist, and how to stay on the right side of food regulations without slowing down your product plans.
Why the FDA Issued This Letter to the Food Industry
On February 5, 2026, the FDA issued a public letter to food manufacturers about voluntary “no artificial colors” labeling claims. The letter signals how the agency plans to approach enforcement when these claims are used on foods intended for human consumption.
At the center of this update is a long-standing regulatory challenge. Under U.S. law, the definition of “artificial color” does not clearly distinguish between colors made from natural sources and synthetic dyes that require FDA certification. As food companies transition away from FD&C certified colors, this definition can create confusion when labeling products.
To address this, the FDA announced it intends to use enforcement discretion for certain voluntary claims. In simple terms, this means the agency does not plan to take action under misbranding rules when specific “no artificial colors” statements are used correctly.
How the FDA Interprets “No Artificial Colors” Claims
The FDA’s letter focuses on foods that do not contain FD&C certified colors listed under 21 CFR Part 74. When those certified colors are fully absent, the agency does not intend to enforce misbranding provisions related to certain voluntary claims.
The claims covered by this enforcement discretion include:
- Made without artificial food colors or colorings
- No artificial colors or coloring
- No added artificial colors or coloring
However, this does not mean all color-related claims are automatically acceptable. The FDA still expects labels to be truthful and not misleading. If your product contains any FD&C certified colors, these claims would not apply.
It is also important to understand what the FDA means by “artificial color.” In regulatory terms, this refers to color additives broadly, not just petroleum-based dyes. Even colors derived from natural sources must be reviewed and approved through the FDA’s color additive petition process before they can be used.
This is where many food businesses run into trouble. Marketing teams may focus on ingredient sourcing, while regulatory teams focus on approvals. Food compliance requires both to align.
Common Compliance Risks for Food Manufacturers
Even with the FDA’s enforcement discretion, risk does not disappear. Several common issues continue to trigger compliance concerns.
One frequent problem is incomplete ingredient review. A finished product may not include FD&C certified colors, but an ingredient blend or processing aid might. If this is overlooked, a “no artificial colors” claim could still be misleading.
Another risk involves supplier documentation. If you rely on supplier assurances without verifying regulatory status, you may lack the evidence needed to support your label claims during an inspection or inquiry.
Inconsistencies between the ingredient statement and front-of-pack claims also matter. The FDA expects claims and ingredient lists to tell the same story. If they do not, enforcement discretion may not protect you.
This is where structured fda food compliance reviews become valuable. Reviewing formulations, supplier specifications, and label language together helps identify gaps early, before products reach the market.
How This Guidance Affects Products Sold Outside the U.S.
Many food companies sell the same product in multiple regions. While the FDA’s letter applies to the U.S. market, other regulators approach color additives differently. In Canada, Health Canada applies its own food coloring rules and labeling expectations. A claim acceptable in the U.S. may still require review or adjustment for the Canadian market.
Similarly, the European Food Safety Authority evaluates food additives, including colors, under EU-specific frameworks. EFSA assessments focus heavily on safety data and authorized uses, which may not align perfectly with U.S. approvals.
If you operate internationally, it is important to avoid assuming that one region’s guidance applies everywhere. Global food compliance often requires tailored labeling strategies, even when the formulation stays the same.
What Food Companies Should Do Next
If you currently use or plan to use “no artificial colors” claims, this FDA update is a good moment to pause and review your approach.
Start by confirming whether any FD&C certified colors appear anywhere in your formulation, including minor components. Then review supplier documentation to confirm the regulatory status of all color additives.
Next, assess whether your claims align with how ingredients are declared on your label. Consistency is key to avoiding misbranding concerns.
Finally, consider a formal label and formulation review before launch or rebranding. Working with a regulatory partner helps ensure that your claims meet FDA expectations while remaining compatible with other food regulations.
If you need support navigating this process, Quality Smart Solutions offers practical guidance across U.S., Canadian, and EU food compliance requirements. You can learn more about our services or reach out directly through our website to discuss your specific product.
Frequently Asked Questions
Does “no artificial colors” mean the same as “all natural”?
No. These claims are regulated differently. “No artificial colors” focuses specifically on the absence of certain color additives, while “natural” claims are broader and subject to separate scrutiny.
Are colors from plant sources always allowed?
Not automatically. Even colors derived from natural sources must be approved by the FDA for use in food. Approval status depends on how the color is made and used.
Can I rely on my supplier’s statement that a color is natural?
Supplier information is helpful, but it is not enough on its own. You should verify regulatory approvals and maintain documentation to support your labeling claims.
Does FDA enforcement discretion mean the rules no longer apply?
No. Enforcement discretion does not change the law. The FDA still expects compliance with all other labeling and food safety requirements.
Does this apply to imported foods?
Yes. Importers are responsible for ensuring that food sold in the U.S. meets FDA labeling requirements, including claims related to artificial colors.
Key Takeaways
- The FDA clarified how it plans to approach “no artificial colors” labeling claims
- Enforcement discretion applies only when FD&C certified colors are fully absent
- Ingredient sourcing, approvals, and label language must align
- International products may still face different regulatory expectations
- Proactive food compliance reviews help reduce risk before products launch
Next Steps
The FDA’s letter provides helpful clarity, but it does not remove the responsibility to review your labels carefully. “No artificial colors” claims can still raise compliance issues if ingredient approvals, supplier documentation, or label language are not fully aligned with FDA expectations.
Taking a proactive approach now can help you avoid relabeling, enforcement questions, or delays once products are already on the market. If you need support reviewing formulations, validating claims, or navigating labeling requirements, Quality Smart Solutions offers practical guidance through its FDA food compliance services. You can also contact our team to discuss your specific product, markets, and compliance goals.
