Hey there! 👋

From ingredient transparency to labeling shifts, the expectations around food products continue to evolve.
This month, we’re highlighting a few key updates shaping the industry and what they mean for brands building and scaling today.

Industry Highlights 💡

FDA Tightens Supply Chain Oversight

Recent FDA enforcement activity is reinforcing a clear shift toward greater supply chain accountability. Across multiple warning letters, the agency flagged gaps in Foreign Supplier Verification Programs (FSVP), food safety plans, and documentation. In several cases, companies failed to properly verify suppliers or maintain required records.

Read more about the DLA PIPER post HERE.

Growing Scrutiny on “GRAS” Ingredients

A recent investigation found that 100+ ingredients currently used in the U.S. food supply have entered the market under the GRAS (Generally Recognized as Safe) pathway.

Importantly, this does not mean these ingredients are unsafe or have been removed but it does highlight how companies can self-determine safety without mandatory FDA review.

As a result, current regulators and policymakers are now pushing for greater transparency and potential reforms to the GRAS system, especially around how ingredient safety is documented and disclosed.

Read more about this report by Food Safety Magazine HERE.

Front-of-Pack Nutrition Labeling Proposal

The FDA continues advancing its proposed front-of-package (FOP) labeling rule, which would require a simplified “Nutrition Info” box on most packaged foods. This label would highlight key nutrients of concern — saturated fat, sodium, and added sugars — classified as low, medium, or high.

Learn more about the FDA announcement HERE.

Client Spotlight: Miami Twist 🥙

Tip of the Month ✅ : Shelf Life Is Not a Guess

Shelf life is primarily determined by product quality and how it changes over time.

However, safety, microbiological stability, and product integrity must always be tested and validated. For certain categories (like perishable products), this is a critical priority.

In other cases — such as dried snacks or crackers — shelf life can be supported by evaluating key parameters like water activity and moisture levels, ensuring the product remains within safe limits to inhibit microbial growth. From there, internal shelf-life studies can assess quality, organoleptic, and sensory changes over time.

Shelf life should be defined through data not assumption.

If you’re evaluating shelf life, determining the most efficient approach, or looking to extend it, our team of in-house food scientists is here to help.

Explore how we can support you at www.evolvefoodconsultants.com

Ask a Food Scientist 📢 :

Why Nutrition Facts Aren’t Always Exact and Why That’s Okay

A recent lawsuit brought attention to something many consumers don’t realize: nutrition labels aren’t always 100% exact.

The FDA allows up to a 20% variance for nutrients that are naturally occurring in foods. Why?
Because real food isn’t static. Nutritional values can shift:

• From lot to lot

• Season to season

• Across growing regions

Even with testing, lead times and operational realities make perfect precision unrealistic.

For brands, this reinforces the importance of:
✔ Strong formulation strategy.
✔ Understanding ingredient variability.
✔ Setting realistic expectations around labelin

How We Can Help 🚀

Navigating these updates alone is tough. Our team is ready to step in as a natural extension of yours:

• Technical Label Reviews: Our Labeling Compliance Review services support your initiatives by reviewing labels and claims to ensure they are properly substantiated while working closely with your marketing and legal teams.

• Food Safety & FSVP Support: We build and implement Food Safety Plans and FSVP programs, ensuring your operations meet regulatory requirements while strengthening supplier verification and risk management.

Ready to evolve? Contact us by clicking right HERE or replying to this email 🙂

Reply with your thoughts, we’d love to hear your thoughts on our new Newsletter format or simply on what you’re working on this month!

Meet the Team: Esther Levy 👩‍🔬

All the Best,
The Evolve Food Team