Food Labeling Reform Is Back — But FDA May Get There First

by: Mindy Abern

Food companies waiting for Congress to act on food labeling reform may be looking the wrong direction.  In April 2026, lawmakers reintroduced the Food Labeling Modernization Act of 2026, which would expand front-of-package nutrition disclosures, revise rules governing nutrition and ingredient claims, and modernize several aspects of food labeling. The bill has been referred to committee and has not yet advanced beyond the introduction stage. But for food manufacturers, retailers, and digital marketplaces, the more immediate pressure point is not on Capitol Hill … it is at the FDA.

The FDA's proposed Front-of-Package Nutrition Labeling rule would require many packaged foods to display a standardized "Nutrition Info" box on the front of packaging. The box would be required to highlight saturated fat, sodium, and added sugars using simplified "Low," "Medium," or "High" indicators. The proposal remains under review, but FDA has identified the initiative as a priority, with a potential final rule projected to come later this year.

If finalized substantially as proposed, the rule would likely trigger a multi-year compliance period. FDA's proposal contemplates compliance dates approximately three years after the effective date for larger companies and four years for smaller companies.

Businesses should not assume that the lack of enacted legislation means labeling requirements will remain static. Even if the Food Labeling Modernization Act does not advance, FDA has authority to implement significant labeling changes through the regulatory process. Many of the concepts found in the legislation (e.g., more prominent nutrition disclosures and clearer consumer-facing information) are already included in ongoing FDA initiatives.

2026 may prove to be an important planning year.  What should you do now?  

  • Audit current front-of-package real estate;

  • Review packaging redesign timelines; 

  • Assess whether existing nutrient content or health claims may need to be reconciled with any new disclosure requirements;  

  • Keep an eye on FDA's rulemaking timeline; and

  • Prepare to move quickly once a final rule is published and the compliance clock starts.

Originally published by InfoLawGroup LLP. If you would like to receive regular emails from us, in which we share updates and our take on current legal news, please subscribe to InfoLawGroup’s Insights HERE. This summary does not constitute legal advice.

Mindy AbernFDA, Food labeling