Industry
AGOA, GRAS and what expires in December
AGOA's authorisation, the FDA GRAS comment window and US facility registrations all run out in December. Two will stop a shipment if you miss them.
December is unusually crowded this year, and some of what expires in it is administrative rather than interesting — which is exactly why it gets missed.
The trade question first
On 19 October, President Ramaphosa said South Africa must prepare for possible exclusion from AGOA as relations with Washington sour. AGOA is currently reauthorised only through December 2026.
Separately, in late July the US announced 10–12.5% tariffs on 60 countries over forced-labour enforcement. Among AGOA countries, only Angola, Nigeria and South Africa were affected.
Neither of these is a flavour story on its own. Both are landed-cost stories, and landed cost is what decides whether a formulation that works is a product that ships.
The diary
Late November 2026 — Mexico's new additive framework takes effect. Published on 21 August, it replaces the 2012 rules outright.
9 December — FDA GRAS comments close. This is the one with the longest tail: the proposal would make notification mandatory for all GRAS substances and does not separately exempt FEMA GRAS conclusions, which cover roughly 3,050 flavour ingredients.
10 December — the end of the civil-society countdown pressing for R3337 approval. A campaign target, not a legal deadline.
14 December — the US salt substitute rule takes effect across 139 food standards.
31 December — FDA facility registration renewals are due, and AGOA's current authorisation expires.
1 January 2027 — Texas SB 25 warning labels begin; California AB 418 bans Red 3, potassium bromate, brominated vegetable oil and propylparaben.
February 2027 — the South African Budget, and the next real decision point on the sugar tax.
The one most likely to catch somebody
The FDA facility registration renewal. Domestic and foreign facilities supplying food for US consumption must renew between 1 October and 31 December 2026, and that includes South African exporters of ingredients.
It is a form. It is also a hard stop — an unregistered facility's shipments do not arrive, and no amount of being otherwise compliant fixes it at the border. Of everything on this list it is the least interesting and the most capable of ruining a quarter.
Reporting: Reuters via CNBC Africa · Center for Global Development · FDA · flavorist.com
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