The ultra-processed label fight names flavour

Most regulation reaches a flavour house indirectly — it restricts an ingredient, or it puts a number on a label, and the reformulation work follows. The ultra-processed food debate is different, because the definitions being drafted name flavourings explicitly.

California went first

AB 2244, signed on 28 September, creates a voluntary non-UPF label. A product does not qualify if it contains dyes, flavour enhancers, non-sugar sweeteners, or taste-manipulating processing aids.

Read that list again. It is not a safety restriction and it is not a quantity threshold. It is a category exclusion, and "flavour enhancer" and "taste-manipulating processing aid" are both inside it. A product using them cannot carry the badge, regardless of dose, origin or whether the ingredient is otherwise entirely permitted.

The federal definition is the bigger one, and nobody has seen it

The United States still has no published federal definition of ultra-processed food. The text is under White House review and has not been released.

Existing definitions in the literature — the ones a federal version would draw on — commonly single out flavouring agents and flavour enhancers as markers of ultra-processing. If that framing survives into a federal definition, it becomes the reference point for every scheme built on top of it.

Why voluntary is not the same as harmless

A voluntary label looks optional until retailers start asking for it. The definitions written into a voluntary scheme are the definitions available when somebody later drafts a mandatory one, and they rarely get looser on the way.

The useful exercise now is not compliance, because there is nothing yet to comply with. It is knowing which of your current systems would be caught by a "flavour enhancer" or "taste-manipulating processing aid" reading, and what the alternatives would cost — in formulation terms, not just in price.

Two hard dates alongside it

From 1 January 2027: Texas SB 25 warning labels take effect, and California AB 418 bans Red 3, potassium bromate, brominated vegetable oil and propylparaben.

Those are bans with dates, which makes them easier to plan for than a definition nobody has published. Colour and flavour travel together in a lot of compounded systems, so a Red 3 reformulation is frequently not only a colour job.

Reporting: flavorist.com · Congressional Research Service · Food Safety Magazine