Two US rule changes that reach SA exporters

Two things happened in the United States this month that matter to anyone shipping food or flavour ingredients there — and the second is the more consequential by a distance.

Salt substitutes, now allowed in standardised foods

On 9 October the FDA finalised a rule permitting salt substitutes in standardised foods whose standards of identity specify salt. It amends 80 standards directly and 59 more by cross-reference — 139 in total — and takes effect on 14 December 2026.

The interesting part is what it does not do: it lists no specific substitutes. Instead it defines a salt substitute functionally, as any safe and suitable ingredient that does salt's job. That is a deliberately wide door.

For a flavour house this reads as demand, not paperwork. Potassium chloride is the usual substitute and it brings a bitter, faintly metallic note with it. Widening where it may be used widens the need for savoury systems that cover that note without flattening everything else.

The GRAS proposal is the structural one

The FDA has proposed making notification mandatory for all GRAS substances — including those already in food. Comments close on 9 December 2026. Substances currently sold on a self-affirmed basis would get a streamlined 12-month submission window.

Here is the part that matters to flavours specifically: the proposal does not separately exempt FEMA GRAS conclusions, or other expert-panel determinations made outside the FDA. Roughly 3,050 flavour ingredients hold FEMA GRAS status for human food. A regime that does not carve them out is a different regime.

Less noticed, and worth reading: the proposal also expands the Threshold of Regulation exemption beyond food-contact materials to food additives and ingredients. For flavouring substances used at very low levels, that could cut the other way.

None of this is final. It is a proposal with an open comment period, and the comment period is the part of the process where this gets decided.

Also before 31 December

Domestic and foreign facilities supplying food for US consumption must renew their FDA registrations between 1 October and 31 December 2026. That includes South African exporters of ingredients. It is administrative rather than interesting, and it stops shipments just as effectively as the interesting ones.

The FDA also revised its import alert on illegal or undeclared colours on 1 October, which touches compounded flavour-and-colour systems.

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