Global Food and Flavor Industry Law & Regulation Digest: March 14–27, 2026

Here is a summary of law and regulation news in the North American food and flavor industry from March 14 through March 27, 2026.

USDA Product of USA Labeling Standard (March 25-26, 2026), the U.S. Department of Agriculture launched a national public awareness campaign to promote the new voluntary "Product of USA" labeling standard for meat, poultry, and egg products, which went into effect on January 1, 2026. Under the standard, the label is reserved exclusively for products from animals born, raised, harvested, and processed in the United States, closing a prior loophole that allowed imported products to carry the claim after minimal processing . For multi-ingredient meat, poultry, and egg products, all ingredients except spices and flavorings must be sourced from the U.S., and processors must be prepared to document their claims with signed attestations . The voluntary rule has drawn support from U.S. cattlemen's groups while they continue to push for mandatory country-of-origin labeling legislation.

California Non-Ultra Processed Food Certification Bill (March 24, 2026), California Assemblymember Jesse Gabriel introduced AB 2244, a bill that would establish a state certification program for non-ultra processed foods (UPFs) administered by the California Department of Public Health. Under the proposed legislation, independent agents would certify products as non-UPF based on the definition established in California law AB 1264, which identifies UPFs as any food or beverage containing specific additives including flavors, emulsifiers, stabilizers, thickening agents, and colors, as well as products with high amounts of saturated fat, added sugar, or sodium . The bill would create a publicly available list of certified products, establish a "California Certified" seal, and require large retailers generating over $10 million in annual sales to prominently display certified products at checkout or store entrances.

FDA Flavored E-Cigarette PMTA Guidance (March 9-14, 2026), the U.S. Food and Drug Administration issued a draft guidance outlining a risk-proportionate approach to evaluating flavored electronic nicotine delivery systems (ENDS) under the Premarket Tobacco Product Application (PMTA) process, with the document clarifying evidentiary standards for determining whether products are "appropriate for the protection of the public health". The guidance categorizes high-risk flavors such as fruit, candy, dessert, and sweet varieties as facing a particularly high evidentiary burden requiring demonstration of significant added benefits for adult smokers compared with tobacco-flavored products, while lower-risk flavors including menthol, mint, and spices may require a smaller demonstrated adult benefit . The Campaign for Tobacco-Free Kids issued a statement on March 10 criticizing the guidance for lowering the scientific standard for certain flavors and ignoring evidence that youth shift to whatever flavors remain available.

California Class Action Juice Labeling Lawsuit (March 16, 2026), a federal judge in California ruled that a class action lawsuit alleging Tree Top mislabels some juice products as "100% juice" despite containing synthetic ingredients can proceed. The ruling represents a significant development in food labeling litigation, as plaintiffs claim the products contain ingredients that contradict the "100% juice" representation.

Celestial Seasonings "All Natural" Flavor Lawsuit (March 2026), Celestial Seasonings, Inc. was sued for allegedly falsely advertising its herbal teas as having "All Natural" flavors despite containing citric acid. The complaint targets five specific tea products, adding to the growing body of litigation challenging "natural" claims on flavored food and beverage products.

New York Dunkin' Refreshers Flavor Labeling Dismissal (March 2026), a New York federal judge dismissed a lawsuit claiming that Dunkin' falsely advertised its "Refresher" beverages as containing real fruit, ruling that menu labels describe flavor rather than ingredients. The decision establishes an important precedent distinguishing between flavor representations and ingredient claims in beverage labeling.

TTB Low and No Alcohol Beverage Guidance (March 2026), the Alcohol and Tobacco Tax and Trade Bureau (TTB) released guidance regarding low and no alcohol beverages via a presentation on the agency's website, providing an overview of regulatory requirements for this growing product category. The guidance addresses labeling and formulation standards for reduced-alcohol and alcohol-removed beverages.

Here is a summary of law and regulation news in the South American food and flavor industry from March 14 through March 27, 2026.

Brazil Chocolate Composition Standards & Cocoa Import Ban (March 18-19, 2026) , Brazil's Chamber of Deputies passed legislation establishing mandatory minimum cocoa content standards for chocolate products, requiring dark chocolate to contain at least 35% cocoa solids (with minimum 18% cocoa butter and 14% non-fat cocoa solids) and limiting other vegetable fats to a maximum of 5%. Milk chocolate must contain at least 25% cocoa solids and 14% dairy components, while white chocolate requires a minimum of 20% cocoa butter and 14% milk solids. The standards will be mandatory on labels for both domestic and imported products . Simultaneously, Brazil's Ministry of Agriculture announced an immediate ban on cocoa bean imports from Côte d'Ivoire, the world's largest cocoa producer, citing concerns that beans from neighboring countries could be mixed into Ivorian export shipments, posing pest and disease risks to Brazil's cocoa sector . The ban applies to fermented and dried cocoa beans and took effect immediately upon announcement.

MERCOSUR Comprehensive Nutrition Labeling Overhaul (Comment Period Closed March 8, 2026) , the Southern Common Market (MERCOSUR), represented by Argentina, notified the World Trade Organization of a draft resolution (GMC Resolution No. 05/25) proposing a significant overhaul of nutritional labeling regulations for packaged foods across member states including Brazil, Argentina, Uruguay, and Paraguay. Key proposed changes include mandatory declaration of "total sugars" and "added sugars" on nutrition facts panels, updated Daily Reference Values (VDRs), and highly specific formatting requirements for nutrition tables covering fonts, colors, layouts, and rounding specifications . The deadline for submitting comments on the proposal was March 8, 2026, and if adopted, the regulation would consolidate and replace four existing MERCOSUR labeling rules with staggered compliance periods of 12 to 60 months depending on product type and business size.

MERCOSUR Packaged Food Labeling Overhaul (Comment Period Closed March 8, 2026) , MERCOSUR additionally proposed a comprehensive update to packaged food labeling requirements through draft GMC Resolution No. 03/25 Rev. 1, notified by Argentina to the WTO on January 7, 2026, with the comment deadline also closing on March 8, 2026. The draft introduces stricter rules on legibility and presentation, significantly tightens ingredient declaration requirements by lowering the composite ingredient disclosure threshold from 25% to 5%, and mandates clearer declarations for additives . The proposal strengthens prohibitions on misleading claims and replaces current regulations GMC No. 26/03 (Technical Regulation for Labeling of Packaged Foods) and GMC No. 06/94 (Declaration of Ingredients). Staggered transition periods of 12 to 60 months are proposed for different product categories.

Chile Food Fortification Guide Revision (Comment Period Closed March 25, 2026) , Chile's Ministry of Health proposed revisions to the country's Food Fortification Guide (Resolution No. 393/02), with a comment period that closed on March 25, 2026. The revision updates the scope of the "Prohibited Foods for Nutrient Fortification" list, expanding coverage to include all foods sweetened with traditional sugar, specialty sugars, non-nutritive sweeteners, sugar alcohols, or any other sweetening ingredients . The expanded categories include confectionery and similar products, jams and similar products, and sugars and syrups, ensuring that these products cannot be fortified with vitamins, minerals, probiotics, or other physiologically functional substances, thereby preventing high-sugar products from misleading consumers through fortification claims.

Brazil ANVISA Food Labeling Public Consultations (Closed March 9, 2026) , Brazil's National Health Surveillance Agency (ANVISA) conducted two public consultations on packaged food labeling regulations with comment periods that closed on March 9, 2026. Public Consultation No. 1357 proposed revisions to general packaged food labeling rules including requirements for ingredient lists to use sales names and list components in descending order by weight, mandatory high-contrast colors for labeling information with minimum 6-point font size, redefinition of "small packaging" as visible surface area under 15 cm² (previously 10 cm²), and enhanced allergen warnings requiring "contains (specific allergen)" statements alongside mandatory declarations for the food additive tartrazine and sulfites at levels ≥10 mg/kg . Public Consultation No. 1358 proposed comprehensive nutritional labeling regulations establishing voluntary labeling for products with label area ≤100 cm² (excluding special dietary products), alcoholic beverages, and flavors and mixed flavorings without nutritionally significant additives, while mandating front-of-package warning labels in black-on-white format for products exceeding thresholds for added sugars, saturated fat, or sodium.

Here is a summary of law and regulation news in the Asian food and flavor industry from March 14 through March 27, 2026.

India Directorate General of Trade Remedies (March 13, 2026) , India initiated an anti-circumvention investigation to determine whether countervailing duties imposed on saccharin imports from China are being circumvented through shipments routed via Thailand . The probe was launched following applications from Swati Petro Products and Blue Jet Healthcare, who alleged that saccharin exported from Thailand is not manufactured there but is of Chinese origin and merely transshipped to avoid existing duties that have been in force since February 2025 . Saccharin is widely used across food and beverage, personal care, table-top sweeteners, and pharmaceutical applications, and if the Directorate General of Trade Remedies finds circumvention, it will recommend extending the countervailing duty to imports from Thailand .

South Korea Ministry of Food and Drug Safety (March 3-19, 2026) , South Korea notified the World Trade Organization of proposed revisions to its Food Additives Standards and Specifications under notification numbers G/SPS/N/KOR/840 and G/SPS/N/KOR/841, with key amendments including revised sweetener usage standards, strengthened management requirements for flavoring substances, expanded nutritional fortifier designations, and updated specifications for sulfites, phosphates, and other additives . The proposed regulations, based on the Codex Alimentarius General Standard for Food Additives (CODEX STAN 192-1995), also include revisions to component specifications and比重 measurement testing methods . WTO member countries were invited to submit comments by May 2, 2026, with the final effective date yet to be determined .

Japan Consumer Affairs Agency (March 23, 2026) , Japan proposed revisions to the food additive standards under the Food Sanitation Act, amending the usage standards for potassium metabisulfite, sodium hydrosulfite, sodium metabisulfite, sodium sulfite, sulfur dioxide, and zinc gluconate based on changes in target food usage quantities and revisions to target food names . The proposed amendments were notified to the World Trade Organization, and the comment period for stakeholders closed on March 23, 2026 . The revisions will take effect as soon as possible after publication, impacting manufacturers using these preservatives and processing aids across the food and beverage sector .

China National Health Commission & State Administration for Market Regulation (Effective March 2, 2026) , China's revised National Food Safety Standards for food additives, jointly released by the NHC and SAMR on September 25, 2025, officially entered into force on March 2, 2026 . The final standards cover several food additives including L-Malic Acid, Xanthan Gum, Ammonium Carbonate, and Acorn Shell Brown, establishing updated specifications for their use in food products . Stakeholders were advised to conduct their own review of the regulations to assess any market or regulatory effect on their business operations in the Chinese market .

Myanmar Food and Drug Board of Authority (Effective April 5, 2026) , Myanmar announced that Order No. 1/2026, establishing mandatory microbiological standards for pre-packaged foods, will take effect on April 5, 2026, following a three-month transitional period after its January 5 issuance . The regulation applies to 16 categories of ready-to-eat foods including dairy, bakery products, meats, seafood, sauces, seasonings, and prepared foods, requiring that specified harmful pathogens be absent in most categories and setting maximum allowable limits for general microorganisms, with canned and heat-processed foods required to meet commercial sterility standards . The standards were notified without prior submission to the World Trade Organization or ASEAN, prompting calls for stakeholders to assess potential market access implications .

Myanmar Ministry of Health (July 20, 2027 Effective Date) , Myanmar submitted a notification (G/TBT/N/MMR/13) to the World Trade Organization on March 16, 2026, announcing new labeling regulations requiring all pre-packaged food products to display a unique Food Product Code to strengthen traceability and consumer verification . The regulation, adopted on January 20, 2026, mandates that food operators obtain the unique code through the online Food Product Declaration System, which can be displayed via direct printing, adhesive stickers, or QR codes . An 18-month transition period has been provided, with the new rules taking effect on July 20, 2027; non-compliant products after this date will face enforcement actions under the National Food Law Article 31 . WTO members may submit comments to the Myanmar FDA Food Control Department by June 30, 2026 .

China National Health Commission & State Administration for Market Regulation (Effective March 16, 2027) , China's mandatory national food safety standard for prepackaged food labeling, GB 7718-2025, was released on March 27, 2025, and establishes a two-year transition period with enforcement beginning March 16, 2027 . The standard applies to prepackaged foods offered directly or indirectly to consumers, requiring labels to be clear, prominent, accurate, and in standard Chinese characters . Key provisions include a prohibition on health function claims for non-health foods, mandatory allergen declarations (cereals with gluten, crustaceans, fish, eggs, peanuts, soybeans), digital labeling options, and specific labeling requirements for imported foods including Chinese ingredient lists, importer information, and China registration numbers . Exemptions from shelf-life declarations apply to wine with alcohol content ≥10%, vinegar, food grade salt, solid sugars, and monosodium glutamate .

Singapore Food Agency (Current as of March 21, 2026) , Singapore's Food Regulations under the Singapore Food Agency Act 1973 (Chapter 283) maintain strict provisions prohibiting false, misleading, or deceptive statements on food labels . Under Regulation 9, no written or pictorial matter on food labels may include claims suggesting therapeutic or prophylactic action, that the food will prevent or cure diseases, that health improvements may be achieved by consumption, or that other foods are unsafe . The regulations also prohibit claims that an ingredient permitted by regulations is unsafe, and labels must not include any statements that may be interpreted as medical advice . The current version reflects amendments made in January 2026 .

Here is a summary of law and regulation news in the African food and flavor industry from March 14 through March 27, 2026.

East African Community Gum Arabic Standards (March 16-18, 2026) , the East African Community (EAC), through the Tanzania Bureau of Standards (TBS), officially released draft standards for gum arabic—DEAS 1326:2026 (Specification) and DEAS 1327:2026 (Code of Practice for Harvesting, Handling, Processing, and Storage)—representing the region's first unified standards for food-grade gum arabic . The draft specification establishes strict quality parameters including gum arabic total content ≥95% (dry basis), pH range of 4.5–7.0, drying loss ≤15%, total ash ≤4%, and acid-insoluble ash ≤0.5%, with microbiological limits requiring total plate count ≤10³ CFU/g and absence of E. coli and Salmonella . The standards classify gum arabic into three grades based on particle size and foreign matter content, and were notified to the WTO on March 16, 2026, with a public comment period open until May 15, 2026 . Rwanda Standards Board (RSB) issued a separate public review notice on March 9, 2026, inviting comments on the same draft East African Standards by May 9, 2026.

Tanzania Solid Flavored Beverage Standard Revision (March 10, 2026) , Tanzania notified the World Trade Organization under document G/TBT/N/TZA/1528 of a revised draft standard for solid flavored beverages containing nutritive sweeteners, with the public comment period set to run for 60 days . The draft revision establishes comprehensive requirements including scope, normative references, terminology, general and specific product specifications, limits for food additives and heavy metal contaminants, production hygiene standards, microbiological criteria, detailed packaging and labeling requirements, and corresponding testing methods for each parameter . The revision is intended to align with current food safety requirements and provide clear quality benchmarks for non-alcoholic flavored beverage products in the Tanzanian market.

Kenya COC/PVoC Certification Regime Changes (Effective March 1, 2026) , the Kenya Bureau of Standards (KEBS) announced that as of March 1, 2026, the pre-export verification of conformity (PVoC) program for imports was adjusted, with the full restoration of mandatory Certificate of Conformity (CoC) requirements for shipments from designated countries . A transition period from February 9 to February 28, 2026, had allowed for destination inspection (DI) at 0.6% of cargo value, but after March 1, shipments without a valid CoC certificate are subject to destination inspection plus a penalty of 5% of cargo value . The CoC application process requires import documentation including the IDF form issued by the Kenyan importer, product test reports based on Kenya Standards (KS) or international standards, commercial invoices, packing lists, and completed application forms, with certificates generally issued within approximately 10 working days.

Kenya KEBS Certification Processing Time Reduction (Effective March 3, 2026) , the Kenya Bureau of Standards (KEBS) announced a reduction in the food production certification processing period from 77 days to 57 days, effective March 2026, a change designed to encourage value addition by farmers and food processors by shortening the waiting period for production permits . The certification process requires applicants to be registered enterprises with KEBS, purchase relevant International Organization for Standardization (ISO) standards from the KEBS website, undergo site inspections for hygiene and raw material quality, and have end-product samples tested at KEBS laboratories over 21–28 days . KEBS quality assurance officer Thomas Asoo emphasized that non-compliant producers face penalties including fines up to Sh2 million, imprisonment, product destruction, or business closure.

South Africa QUID Labeling Enforcement Action (March 10-11, 2026) , South African retailer Checkers, operated by Shoprite Holdings, withdrew its private-label Ready to Braai Smokey Stuffed Chicken Breast product from shelves following a customer complaint alleging that packaging contained 264 grams of sauce versus 246 grams of chicken (49% of total weight), contradicting the product's Quantitative Ingredient Declaration (QUID) claim of 62% chicken breast . The incident triggered scrutiny under Regulation 26 of the Regulations Relating to the Labelling and Advertising of Foodstuffs (R146), which mandates percentage declarations for ingredients emphasized in product names or packaging imagery . Shoprite confirmed the withdrawal resulted from a production processing error at the manufacturing facility where smaller chicken portions were incorrectly packed, and stated corrective measures have been implemented to strengthen quality control processes, with plans to improve transparency by making full ingredient lists available for all private-label products sold online.

Kenya Enhanced Food Import Controls Timeline (Indicative Date: June 30, 2026) , the Kenya Bureau of Standards (KEBS) and other Kenyan border agencies continue implementation of enhanced import controls and inspection mechanisms under WTO Article 5.1 notifications, with a definitive implementation date set for June 30, 2026 . The enhanced framework aims to develop modern systems for notifying stakeholders about controls, establish infrastructure to detect food hazards including early warning systems at all points of entry, and train border agency staff on import alerts and rapid alert tests . Kenya has received capacity-building support from TradeMark Africa (TMEA) and the European Union for equipment procurement and laboratory refurbishment for food hazard detection, though continued assistance is required for full implementation of the enhanced inspection regime.

Here is a summary of law and regulation news in the European food and flavor industry from March 14 through March 27, 2026.

EU Wine and Spirit Drink Regulation (EU) 2026/471 (March 18, 2026 applicability) , the European Commission formally published Regulation (EU) 2026/471 on February 26, 2026, which entered into force on March 18, 2026, amending market rules and labeling requirements for wine, aromatized wine products, and spirit drinks with geographical indications. The regulation introduces mandatory labeling terminology for reduced-alcohol and de-alcoholized grapevine products, requiring terms such as "alcohol-free" (for products below 0.5% ABV) and "reduced alcohol" beginning September 19, 2027, alongside harmonized electronic ingredient and nutrition information requirements accessible via pictograms on packaging . The reform also extends the vine planting authorization scheme indefinitely with 10-year reviews, waives penalties for unused pre-2025 planting rights, and expands eligibility for sectoral support measures including vineyard grubbing-up and green harvesting to address oversupply and declining wine consumption across the EU.

EU Mineral Oil Aromatic Hydrocarbons (MOAH) Contaminant Limits Proposal (March 23, 2026) , the European Union notified the World Trade Organization of a draft regulation (G/SPS/N/EU/930) proposing a comprehensive revision of maximum levels for mineral oil aromatic hydrocarbons (MOAH) in food products under Regulation (EU) 2023/915, with a comment period open to WTO members. The proposal establishes product-specific MOAH limits significantly stricter than the current blanket limits of 0.5 mg/kg for foods with ≤4% fat, 1 mg/kg for 4-50% fat, and 2 mg/kg for >50% fat . New limits target specific categories including oils and fats (proposed at 0.5 mg/kg), cocoa and chocolate products, spices, teas, herbs, infant foods, and importantly for the flavor industry, food additives themselves . The regulation, driven by EFSA findings that MOAH compounds with three or more aromatic rings may have genotoxic and carcinogenic properties, is scheduled to take effect on January 1, 2027, with certain product categories granted transitional periods.

EFSA Food Additives and Flavourings Monitoring Program (Deadline June 30, 2026) , the European Food Safety Authority (EFSA) launched its second pilot data collection under the monitoring program for food additives and flavorings, establishing a June 30, 2026, deadline for submission of analytical, use level, and presence data. The initiative, mandated by Regulations (EC) No 1333/2008 and No 1334/2008, prioritizes five substances for data collection: sorbic acid/potassium sorbate (E 200-202), butylated hydroxytoluene (BHT) (E 321), coumarin, hydrocyanic acid, and theobromine . National food authorities, research institutions, food business operators, and other stakeholders must submit data through EFSA's Data Collection Framework (DCF) using standardized XML formats, with validation and acceptance continuing through August 31, 2026 . The data will support future risk assessments and combined exposure evaluations for multiple chemicals across the European food supply chain.

EU Sugar Import Suspension Proposal (March 14, 2026) , the European Commission announced plans to suspend approximately 700,000 tons of duty-free sugar imports under the "inward processing" regime for at least one year to stabilize falling internal prices and protect EU sugar producers from low-cost cane sugar competition. Agriculture Commissioner Christophe Hansen confirmed that the necessary paperwork is being prepared for submission to the Commission in the coming weeks, with the suspension aimed at addressing market pressures facing European sugar beet growers and processors . The proposal represents a significant trade measure that could tighten European sugar supply, impact confectionery and sweet goods manufacturers reliant on imported sugar, and potentially redirect trade flows toward other markets.

EU Investigation into Central European Grain Import Bans (March 14, 2026) , the European Commission initiated an investigation after Poland, Hungary, and Slovakia imposed unilateral bans on Ukrainian grain and food imports through June 30, 2026, citing competitive pressures on domestic farmers from the surge in Ukrainian agricultural products. The three neighboring countries acted in response to farmer protests over a glut of grain that had depressed local prices, with Slovakia additionally citing detection of banned pesticides in Ukrainian grain shipments . The Commission, which manages trade policy for the 27 member states, objected to the unilateral measures while acknowledging the challenges posed by the EU's suspension of tariffs on Ukrainian goods—a wartime measure set to expire in June 2026—and emphasized the need for solutions consistent with EU legal frameworks . The dispute highlights tensions between supporting Ukraine's economy and protecting domestic agricultural sectors across Central Europe.

Norway GM Feed Ingredients Alignment Proposal (March 27, 2026) , the Norwegian Food Safety Authority launched a consultation on proposed regulatory changes that would allow genetically modified (GM) feed ingredients approved by the European Food Safety Authority (EFSA) to be freely traded in Norway for aquaculture feed use, with a consultation deadline of June 18, 2026. The proposal addresses growing supply risks for Norway's aquaculture sector, which relies on imported feed ingredients for over 90% of its needs, and seeks to eliminate competitive disadvantages with EU member states and the UK where such GM feed ingredients are already permitted . The changes would exempt processed GM feed ingredients from Norway's traditionally strict approval system provided they have undergone EFSA safety assessment, potentially expanding ingredient sourcing options for fish feed manufacturers.

EFSA Flavoring Group Evaluation FGE.09Rev4 (Published March 2026) , the EFSA Panel on Food Contact Materials, Enzymes, Flavourings and Processing Aids (CEF) published Scientific Opinion on Flavouring Group Evaluation 9, Revision 4 (FGE.09Rev4), assessing 21 flavoring substances including secondary alicyclic saturated and unsaturated alcohols, ketones, and esters. The evaluation concluded that 20 of the 21 substances—including p-menthan-3-one [FL-no: 07.059] and menthol 1-and 2-propylene glycol carbonate [FL-no: 09.843]—do not raise safety concerns at estimated dietary intake levels based on the Maximized Survey-Derived Daily Intake (MSDI) approach, with no genotoxic potential identified . For the remaining candidate substance [FL-no: 07.207], the Panel requested additional toxicity data including further metabolism and/or toxicity studies before completing safety assessment.

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