On June 22, 2025, Texas Governor Greg Abbott signed Senate Bill 25 (SB 25) into law, significantly tightening food labeling regulations in the state. Effective January 1, 2027, all food and beverage products sold in Texas that contain one or more of the 44 substances listed in the bill will be required to display a warning label.
The law specifically targets ingredients such as titanium dioxide and certain FDA-approved food colorants, including Red 40. As previously reported, SB 25 passed the Texas House on May 26, 2025, with bipartisan support and endorsement from U.S. Department of Health and Human Services Secretary Robert F. Kennedy, Jr.
SB 25 amends the Texas Health and Safety Code by adding Sections 431.0815, 431.0816, and 431.0817 to Subchapter D, Chapter 431. Under the new requirements, companies must either remove any of the listed ingredients from their products or apply a warning label “in a prominent and reasonably visible location.” The required warning reads:
“WARNING: This product contains an ingredient that is not recommended for human consumption by the appropriate authority in Australia, Canada, the European Union, or the United Kingdom.”
This labeling requirement applies to any food product label “developed or copyrighted” on or after January 1, 2027. Non-compliance may result in significant penalties, including civil fines of up to $50,000 per day for each offending product, in addition to injunctive relief sought by the Texas Attorney General.
Importantly, Section 431.0815 stipulates that the warning label must be used if the ingredient appears on the FDA-required label and is present in a product intended for human consumption. This provision was added via an amendment introduced by Representative Lacey Hull on May 25, 2025.
While the law applies specifically to products sold in Texas, its impact is expected to be far-reaching, prompting reformulations and labeling changes across the broader U.S. food and beverage industry. The law will officially take effect on September 1, 2025.
The List of 44 Ingredients that Will Need to Apply a Warning Label
|
(1) |
acetylated esters of mono- and diglycerides(acetic acid ester) |
|
(2) |
anisole |
|
(3) |
azodicarbonamide (ADA) |
|
(4) |
butylated hydroxyanisole (BHA) |
|
(5) |
butylated hydroxytoluene (BHT) |
|
(6) |
bleached flour |
|
(7) |
blue 1 (CAS 3844-45-9) |
|
(8) |
blue 2 (CAS 860-22-0) |
|
(9) |
bromated flour |
|
(10) |
calcium bromate |
|
(11) |
canthaxanthin |
|
(12) |
certified food colors by the United States Foodand Drug Administration |
|
(13) |
citrus red 2 (CAS 6358-53-8) |
|
(14) |
diacety |
|
(15) |
diacetyl tartaric and fatty acid esters of mono-and diglycerides (DATEM) |
|
(16) |
dimethylamylamine (DMAA) |
|
(17) |
dioctyl sodium sulfosuccinate (DSS) |
|
(18) |
ficin |
|
(19) |
green 3 (CAS 2353-45-9) |
|
(20) |
interesterified palm oil |
|
(21) |
interesterified soybean oil |
|
(22) |
lactylated fatty acid esters of glycerol and propylene glycol |
|
(23) |
lye |
|
(24) |
morpholine |
|
(25) |
olestra |
|
(26) |
partially hydrogenated oil (PHO) |
|
(27) |
potassium aluminum sulfate |
|
(28) |
potassium bromate |
|
(29) |
potassium iodate |
|
(30) |
propylene oxide |
|
(31) |
propylparaben |
|
(32) |
red 3 (CAS 16423-68-0) |
|
(33) |
red 4 (CAS 4548-53-2) |
|
(34) |
red 40 (CAS 25956-17-6) |
|
(35) |
sodium aluminum sulfate |
|
(36) |
sodium lauryl sulfate |
|
(37) |
sodium stearyl fumarate |
|
(38) |
stearyl tartrate |
|
(39) |
synthetic trans fatty acid |
|
(40) |
thiodipropionic acid |
|
(41) |
titanium dioxide |
|
(42) |
toluene |
|
(43) |
yellow 5 (CAS 1934-21-0) |
|
(44) |
yellow 6 (CAS 2783-94-0) |
About Us
The Food Division of CIRS Group was established in 2012 and has a professional team specializing in US GRAS notices. The Food Division has extensive experience in various fields, covering GRAS, new food ingredients, new food additives, food contact materials, synthetic biology foods, EU Novel Foods, dietary supplements, and special dietary foods.
CIRS operates a fully-owned subsidiary in the US. By leveraging the expertise of the CIRS USA and the international team, it can provide enterprises with various US food services, including but not limited to:
- US FDA GRAS Notice;
- US FDA Dietary Supplement Structure/Function Claim Notification;
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- US FDA Registration of Food Facilities; and
- US Food Label/Advertisement Information Review.
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