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Red No. 3 and the 2027 additive deadlines.

FDA's January 15, 2027 deadline to remove FD&C Red No. 3 from food, California's Food Safety Act additive ban effective January 1, 2027, and Texas SB 25 warning labels, with a reformulation and label checklist.

By Apex Food CompliancePublished October 22, 20265 min read

Three additive and labeling changes converge in January 2027. Each has its own scope, so check them separately against every formula and supplier specification.

FD&C Red No. 3: January 15, 2027

FDA revoked the authorization to use FD&C Red No. 3 (erythrosine) in food. Food manufacturers have until January 15, 2027 to reformulate, and FDA has encouraged companies to finish sooner. Red No. 3 often hides in candy, frostings, decorations, cherries and colored coatings supplied as ingredients, not just in your own color additions.

California Food Safety Act (AB 418): January 1, 2027

California bans four additives in food sold in the state: brominated vegetable oil, potassium bromate, propylparaben and Red Dye No. 3. Potassium bromate is the one bakeries most often need to check, because it has been used as a flour improver. FDA has separately revoked the federal authorization for brominated vegetable oil.

Texas SB 25 warning labels: January 1, 2027, in litigation

Texas requires a warning statement on food labels developed or copyrighted on or after January 1, 2027 that contain listed ingredients. Texas regulators have said that changing an existing label after that date counts as a new label. In February 2026 a federal court blocked enforcement against members of the trade associations that sued, and the state appealed. Check the current status before relying on either outcome.

Watch the timing trap: a label change made for an unrelated reason in 2027 could pull a Texas SKU into SB 25. Coordinate reformulation and label projects so you change each label once.

Reformulation checklist

Search every formula, sub-recipe and ingredient specification for the listed additives, including colors inside purchased components.
Ask suppliers for written confirmation, and update specifications and letters of guarantee.
Qualify replacements for color, function and stability, and run shelf-life checks where the change could affect them.
Run reformulations through change management so HACCP, allergen and label reviews are triggered.
Update ingredient statements and confirm the new label against the final formula before printing.
Plan the inventory cutover so non-compliant packaging and finished goods don't ship after the deadline.

Every date here is tracked with a live countdown on our Compliance Calendar.

Sources: FDA on Red No. 3 · FoodNavigator on AB 418 · Haynes Boone on SB 25