OMB Releases Spring 2025 Unified Agenda of Regulatory Actions

Notably, FDA intends to issue a proposed rule this fall to reform the generally recognized as safe (GRAS) framework by requiring mandatory submission of GRAS notices for the use of human and animal food substances that are purported to be GRAS; as well as a final rule on front-of-package nutrition labeling next spring.  There are also several new rulemaking actions including the (already issued) proposed and direct final rules revoking 52 standards of identity¹. Notable rulemaking actions from the last edition that are absent from the Spring 2025 Unified Agenda include FDA's proposed rule to eliminate certain written assurance requirements from 21 CFR § 117.136 and FSIS's proposed Salmonella framework².  In addition to highlighting the most significant priorities for these agencies, we provide charts in Appendix A that list other relevant rulemakings included on each agency's agenda.

We caution that the dates included in the Unified Agenda³ are not commitments to act on or by the date shown. Rather, they simply indicate the agencies' aspirations. Note also that the dates for some planned actions have already passed. Rather than focusing on projected dates, the Unified Agenda is a valuable tool to identify the substantive issues the agencies consider to be priorities for rulemaking.

FDA Priorities

Although many entries from the Fall 2024 Unified Agenda have been carried forward to the Spring edition, there are some notable changes reflecting new administration priorities, including the revocation of 52 standards of identity and amendments to the GRAS process. The majority of the carried forward rules remain at the same stage but with new dates of completion. However, FDA’s Spring 2025 priorities do not include certain rulemaking actions that were included in the Fall 2024 Unified Agenda, such as the Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human proposed rule, which would eliminate certain written assurance requirements from 21 CFR § 117.136. As noted above, the projected dates are not commitments to complete the action by the identified dates but rather reflect the agency’s goal.

• Key Priorities: Labeling and Ingredient Safety:
  • Substances Generally Recognized as Safe: This proposed rule would amend the GRAS regulations in 21 CFR parts 170 and 570 to require the mandatory submission of GRAS notices for the use of human and animal food substances that are purported to be GRAS. Food substances include both ingredients and substances added indirectly (such as from food packing). Food substances that are listed or affirmed as GRAS for the intended use by regulation, or for which FDA has already issued a “no questions” letter on its GRAS notice inventory, would be exempted. FDA anticipates the proposed rule would require that FDA maintain and update a public-facing GRAS notice inventory for all substances that are the subject of mandatory GRAS notice for its conditions of intended use as well as the process under which FDA would determine that a substance is not GRAS. (Proposed Rule: October 2025).
  • Front-of-Package Nutrition Labeling⁴: This final rule would require the front of food labels to display certain nutrition information to help consumers, including those who are busy and those with lower nutrition knowledge, make more informed dietary choices. This rule would also amend certain nutrient content claim regulations to align with current nutrition science and ensure consistency in labeling. (Final Rule: May 2026).
  • Rulemaking to Provide by Regulation that an Ingredient Is Not Excluded From the Dietary Supplement Definition: This proposed rule would find that a specific ingredient would not be excluded from the dietary supplement definition and that products containing this ingredient could be lawfully marketed as dietary supplements, provided they otherwise meet the definition of "dietary supplement" under section 201(ff) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) and are not otherwise in violation of the FD&C Act. (Proposed Rule: January 2026).
• FSMA-related: One rulemaking under the FDA Food Safety Modernization Act (FSMA) is worth highlighting. Note that the below rule has been published and the comment period has already ended:
  • Requirements For Additional Traceability Records For Certain Foods: Compliance Date Extension⁵: The proposed rule would extend the compliance date for the final rule, "Requirements for Additional Traceability Records for Certain Foods” by 30 months to July 20, 2028. (Comment Period Ended August 4, 2025).
• Standards of Identity: There are a number of rulemakings of interest concerning FDA’s efforts to modernize standards of identity, the first three of which have already been issued:
  • Food Standards of Identity Modernization; Pasteurized Orange Juice: This proposed rule would amend the standard of identity for pasteurized orange juice by lowering the minimum orange juice soluble solids content from 10.5° to 10° Brix. (Proposed Rule: December 2025).
  • Revocation of Food Standards for 11 Products Not Currently Sold: This direct final rule will revoke 11 food standards for foods that are no longer sold in the United States. (Comment Period Ends: July 2025; Direct Final Rule: July 2025).
  • Proposal to Revoke 18 Standards of Identity for Dairy Products: This proposed rule will revoke 18 standards of identity for dairy products. (Comment Period: July 2025).
  • Proposal to Revoke 23 Standards of Identity for Foods: This proposed rule will revoke 23 standards of identity for food. This proposed action would reduce redundant regulatory requirements. (Comment Period: July 2025).
  • Use of Salt Substitutes to Reduce the Sodium Content in Standardized Foods: This final rule would permit the use of salt substitutes in standardized foods in which salt is a required or optional ingredient. The rule is intended to support industry efforts to reduce sodium content in standardized foods. (Final Rule: May 2026).
  • Cheeses and Related Cheese Products; Proposal to Permit the Use of Ultrafiltered Milk: This final rule will amend the FDA regulations to provide for the use of fluid ultrafiltered milk (fluid UF milk), fluid ultrafiltered nonfat milk (fluid UF nonfat milk), fluid microfiltered milk (fluid MF milk), and fluid microfiltered nonfat milk in the manufacture of standardized cheeses and related cheese products. The final rule also provides an exemption for standardized cheeses and related cheese products containing them from labeling fluid UF milk, fluid UF nonfat milk, fluid MF milk, and fluid MF nonfat milk when used along with milk or nonfat milk in standardized cheeses and related cheese products. (Final Rule: December 2025).

USDA Priorities

As with FDA, the USDA priorities include notable changes reflecting new administration priorities. For example, USDA’s Spring 2025 priorities do not include certain rulemaking actions that were listed in the Fall 2024 Unified Agenda, including the proposed Salmonella framework⁶. As noted above, the projected dates are not commitments to complete the action by the identified dates, but rather reflect the agency’s goal. FSIS and AMS have a handful of regulatory priorities that may be of particular interest.

FSIS

• Maximum Line Speed Rates for Young Chicken and Turkey Establishments Operating Under the New Poultry Inspection System: FSIS is proposing to amend the regulations that prescribe the maximum line speed rates under the New Poultry Inspection System (NPIS) to allow NPIS young chicken and turkey establishments to operate at more efficient line speeds. (Proposed Rule: September 2025).
• Maximum Line Speed under the New Swine Slaughter Inspection System (NSIS): FSIS is proposing to amend the pork products inspection regulations to eliminate line speed limits for NSIS establishments and allow NSIS establishments to determine their line speeds based on their ability to maintain process control. (Proposed Rule: September 2025).
• Movement of Adulterated and Misbranded Product: FSIS is proposing to amend its federal meat, poultry, and egg product inspection regulations to make them more consistent and clarify that official establishments that transport adulterated or misbranded products under establishment or FSIS controls to another official establishment for appropriate disposition are not required to notify or obtain permission from FSIS prior to transporting the product. (Proposed Rule: October 2024).
• Revision of the Nutrition Facts Labels for Meat and Poultry Products and Updating Certain Reference Amounts Customarily Consumed: Consistent with the changes that FDA finalized, FSIS is amending its meat and poultry products inspection regulations to update and revise the nutrition labeling requirements for meat and poultry products to reflect recent scientific research and dietary recommendations and to improve the presentation of nutrition information to assist consumers in maintaining healthy dietary practices. (Final Rule: January 2026).

AMS

• National Bioengineered Food Disclosure Standard; Update of the List of Bioengineered Foods (AMS-FTPP-22-0080): AMS intends to issue a proposed rule updating the List of Bioengineered Foods in the National Bioengineered Food Disclosure Standard. (Proposed Rule: April 2026).
• Rescinding National Organic Program; Market Development for Mushrooms and Pet Food (AMS-NOP-22-0063): This final rule would rescind the rule and regulations issued on December 23, 2024, titled, "National Organic Program; Market Development for Mushrooms and Pet Food.” Amendments made to the USDA organic regulations were intended to clarify production and handling requirements for a) organic pet food standards and b) organic mushrooms. (Final Rule: November 2025).

TTB Priorities

TTB’s regulatory priorities are focused on labeling initiatives and updated standards of identity and definitions.

• Major Food Allergen Labeling for Wines, Distilled Spirits, and Malt Beverages: TTB is requesting public comment on possible changes to its alcohol beverage regulations related to allergen labeling. (Final Rule: May 2026).
• Ingredient Labeling of Distilled Spirits, Wines, and Malt Beverages: In response to a U.S. Department of Treasury report, TTB is initiating rulemaking proposing ingredient labeling on alcohol beverage products. (Advanced Notice of Proposed Rulemaking: December 2025).

Appendix A

Please click here for a chart summarizing the key planned regulatory activities of particular interest to the food industry.

Authored by Veronica Colas, Brian Eyink, Chigozie Akah, and Jamie Hannah.