From AFOA General Counsel, Olsson Frank Weeda:

Here is our memorandum entitled, “FDA Releases 2026 Deliverables and Potential Guidance for Human Foods Program.” Note, the 32 Deliverables and 14 Guidances include familiar MAHA themes, including the importance of removing harmful chemicals from food, defining ultraprocessed foods (“UPFs”), implementing front-of-pack (“FOP”) labeling, removing the generally recognized as safe (“GRAS”) “loophole,” and reforming food assistance programs. We advise reviewing where these priorities may impact your business.