During the Biden administration, investments flowed into food synthetic biology (synbio) technologies such as precision fermentation and cell-based meat as well as into other next-generation food ingredients. At the same time, a growing number of startups began introducing ingredients through a self-affirmed generally recognized as safe (GRAS) procedure, which allows companies to determine an ingredient’s safety without a formal FDA review, instead relying on independent expert panels and scientific evidence. However, the appointment of Robert F. Kennedy (RFK) Jr. as secretary of the U.S. Department of Health and Human Services (HHS) under the Trump administration has marked a dramatic political pivot in 2025. RFK Jr. has a long history of skepticism toward processed food ingredients and modern food science. With a deep skepticism toward biotechnology and processed food products, RFK Jr. may impose regulatory slowdowns, trigger funding reviews, and propel a shift away from synthetic and engineered ingredients.
What has happened so far?
The most consequential policy to date is the “Make America Healthy Again (MAHA) Commission,” an executive order issued on February 13, 2025. Other notable actions are as follows:
- On February 5, 2025, HHS issued a directive to FDA to explore rulemaking to stop self-affirmed GRAS pathways for new food ingredients, aligned with RFK Jr.’s MAHA plan. While the outline is directed toward self-affirmed GRAS pathways and is not yet affecting FDA GRAS notices, it has created industry uncertainty, given that since its approval in 2016, self-affirmed pathways have served as a fast track to market for novel food and beverage ingredients — especially those derived from fermentation, enzymatic processes, or engineered microbes.
- On March 24, 2025, West Virginia became the first state to enact a statewide ban on several synthetic food dyes and preservatives, including Blue No. 1, Blue No. 2, Green No. 3, Red No. 3, Red No. 40, Yellow No. 5, Yellow No. 6, butylated hydroxyanisole, and propylparaben. Governor Patrick Morrisey signed House Bill 2354, emphasizing children’s health and state-level food quality. With RFK Jr. attending the bill signing, it publicly endorsed West Virginia’s new ban on food dyes, calling on other states to follow the example and offering federal support through his agency.
- On March 14, 2025, President Trump rescinded Executive Order 14081, “Advancing Biotechnology and Biomanufacturing Innovation for a Sustainable, Safe, and Secure American Bioeconomy,” originally issued on September 12, 2022. The rollback removes a coordinated federal mandate that had accelerated biobased innovation across multiple sectors, including food and agriculture. Originally issued in 2022, the order directed agencies like USDA, the U.S. Department of Energy, the National Science Foundation, and the National Institutes of Health to prioritize R&D funding, develop commercialization incentives through government procurement, and streamline regulatory pathways for emerging technologies such as precision fermentation, cell-based proteins, and engineered food additives. Rescinding the order signals a shift away from these priorities, likely resulting in fewer resources, slower regulatory progress, and reduced institutional support for biotech-driven consumer products.
- In a closed-door meeting with the CEOs of several major food companies — including PepsiCo, General Mills, Smucker’s, Kraft Heinz, and Kellogg’s — RFK Jr. was reported to have pressured these executives to stop the use of artificial dyes in their products, signaling potential upcoming bans. More recently, bills have been progressing in Texas and Arizona that aim to ban artificial food dyes and other additives from foods served at schools or from sale statewide.
How does Lux expect this situation to evolve?
Innovation in ingredients depends on both regulatory certainty and supportive federal funding — two pillars now destabilized under the new administration. The Trump administration’s proposed budget cuts to USDA’s National Institute of Food and Agriculture — a major driver of domestic food systems R&D — threaten to derail innovation programs focused on novel crop development, food safety technologies, and alternative protein research. Beyond funding, regulatory delays are intensifying the risk. Lux anticipates that ingredients companies may soon challenge the administration in court, citing politically motivated slowdowns in the regulatory process for certain additives. Adding fuel to the fire, RFK Jr. announced that HHS would cut 20,000 jobs on March 27. While the restructuring is projected to save taxpayers USD 1.8 billion annually, there are valid concerns about FDA’s capacity to manage the increased workload associated with the enhanced oversight of food additives and ingredient approvals. Lux anticipates several parallel developments that could shape the ingredient innovation landscape:
- Ingredient innovation slows under new regulatory protocols. The most likely outcome is a prolonged period of regulatory uncertainty. New ingredients, especially those involving synbio like precision fermentation and cell-based meat, will face delays or heightened review standards related to toxicology and safety data.
- Favorable pathways appear for health-driven ingredients. If ingredients can demonstrate clear benefits (e.g., metabolic health, cardiovascular health, reduction of blood sugar), they may be exempted from new scrutiny. Functional ingredients with health and performance benefits may find more success, such as plant-derived food additives (e.g., beetroot powder instead of synthetic red dye).
- Political pressure creates dichotomy. Influential Democratic lawmakers — especially those from biotech and food tech hubs in California and Massachusetts — may seek to influence legislative outcomes or regulatory directions if innovation slowdowns threaten jobs and scientific output. But with a narrow House margin, winning enough bipartisan support remains uncertain.
Lux Take: How should clients adapt?
Ingredients and CPG clients should begin auditing regulatory risk immediately, evaluating both existing and pipeline ingredients for vulnerabilities — starting with synbio-derived additives and those previously self-affirmed as GRAS and then building into those that may impact child health or chronic disease. Technologies like ingredient informatics will help expedite product development timelines and help mitigate reformulation challenges. Stakeholders should also adopt a human-centric innovation framework by reframing their value propositions and pivoting toward “functional wellness” narratives and “clean label ingredients,” emphasizing health benefits. To that end, clients should begin proactively investing in and developing technologies that offer alternatives for reducing sugar, salt, and fat, aligning with consumer clean-label expectations. As U.S. approval pathways grow uncertain, the best plan is to prepare for geographic diversification by strengthening go-to-market strategies in regions like Europe or APAC. While clients may continue pursuing their original ingredient innovation strategies in markets outside the U.S., the new administration creates opportunities to explore new directions — particularly those emphasizing simple ingredients.
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