Shifting consumer demand and rising regulatory scrutiny are increasing pressure on the U.S. food and beverage industry to move away from synthetic Federal Food, Drug, and Cosmetic Act colorants and toward natural alternatives.
FDA oversight has intensified, states are adopting policies with ambitious timelines, and clean-label demand has prompted many companies to reformulate or publicly commit to removing artificial colors. Yet significant uncertainty remains as federal signals evolve, state approaches diverge, and the industry navigates a fundamentally different ingredient system.
The transition to non-FD&C colorants presents both risks and opportunities. Without coordination, the industry may face higher costs, supply instability, and uneven implementation. With proactive, system-level action, the transition can strengthen resilience, transparency, and responsiveness across the colorant supply system.
Aligning regulatory frameworks, investing in supply chain capacity, and reducing technical and operational barriers will be essential for a feasible and sustainable transition.
A new report from RTI International details the realities of this full-scale transition, providing recommendations and key takeaways across the supply chain.
in U.S. food & beverage dollar sales contain FD&C colorants
~7% of total dollar sales
Non-FD&C colorant use
has grown steadily
year-over-year
Confectionery & Beverages
are among the most impacted categories
Most acceleration-transition scenarios
rely heavily on imports
Recommendations for Stakeholders
Policymakers and Regulators
For Policymakers and Regulators
Pair regulatory clarity and feasible timelines with incentives structures to help the industry transition (e.g., grants, incentives infrastructure support, risk‑management tools). Proactively engage in dialogue with industry to understand the realities of the supply chain.
Agricultural Stakeholders
For Agricultural Stakeholders (e.g., producers, commodity organizations, universities)
Reduce grower risk and enable scale by prioritizing the most viable domestic feedstocks/waste streams and expanding contract farming or vertically integrated models aligned with projected demand. Seek investment in R&D and knowledge‑sharing to improve high‑pigment varieties, production best practices, and geographic diversification for resilience.
Ingredient Processors and Suppliers
For Ingredient Processors and Suppliers
Secure supply and accelerate adoption by creating market certainty for producers, using contracts or off‑take agreements and vertical integration where helpful, and investing in the processing and extraction infrastructure that matters most for priority feedstocks. Over the longer term, diversify sourcing regions and develop next‑generation solutions (including fermentation where appropriate) to improve stability, tolerance, and performance.
Food Manufacturers
For Food Manufacturers
Build execution capacity by prioritizing easy and low-risk reformulations first, establishing dedicated transition teams, and locking in longer‑term supply agreements and early supplier partnerships to speed reformulation and testing. Start consumer testing and communications early, and coordinate with distributors on any handling or warehousing changes required.
Distribution and Warehousing
For Distribution and Warehousing
Prevent waste and disruption by implementing first expired, first out (FEFO), where shelf life or variability increases expiry risk and by defining scalable handling profiles (temperature/humidity/light) for the subset of sensitive products. Coordinate cutover windows with manufacturers and retailers to avoid stranded inventory under uncertain enforcement timelines.
Retailers
For Retailers
Reduce compliance risk by proactively communicating timelines and expectations with manufacturers and by using merchandising levers such as placement, promotions, and lighting plus staff training to support compliant products and manage appearance changes. Over time, help normalize pricing by supporting scale and sustained demand for compliant products.
For Policymakers and Regulators
Pair regulatory clarity and feasible timelines with incentives structures to help the industry transition (e.g., grants, incentives infrastructure support, risk‑management tools). Proactively engage in dialogue with industry to understand the realities of the supply chain.
Explore the Roadmap
Current State: Widespread Use of FD&C Colorants and Emerging Alternatives
FD&C dyes remain widely present across U.S. retail categories; confectionery and beverage are among the most dye-dependent categories by sales and UPCs.
Non-FD&C label attributes appear at meaningful scale today, but this appearance does not indicate supply chain readiness is sufficient to meet performance requirements for all food and beverage products.
FD&C dyes represent double the current market volume of non-FD&C dyes; notably, this volume does not correlate to the number of products nor consider the replacement rates, which can be 10-fold or higher.
Red, yellow, and orange colorants are among the highest volume across both FD&C and non-FD&C colorants; annatto, beta-carotene, betanin, and curcumin rank as top four non-FD&C colorants.
Candy and beverages are the two product categories most likely to be impacted by the transition away from non-FD&C colorants.
Future Scenarios and Implications of a Rapid Non-FD&C Scale-Up
Regulatory pressure to transition is intensifying, with uncertain system wide impacts.
Expanding federal scrutiny and a growing patchwork of state policies are pushing the food industry toward reduced reliance on FD&C colorants, but the pace and design of this transition could have unanticipated effects on prices, land use, and trade.
The scale-up scenarios represent upper bound or stress test cases rather than likely trajectories.
Because of uncertainty and limited empirical data, the analysis examines extreme demand growth scenarios to illustrate how the system could respond under aggressive or policy driven acceleration, not to predict expected outcomes.
Results show that under extreme transition pressure, markets adjust primarily through prices and imports.
Modeled average price increases across non-FD&C colorants range from roughly 53% under baseline growth to more than 1,000% under upper bound demand scenarios.
Colorant Profiles
Colorant profiles in this report are organized by active color compounds rather than by FDA-regulated ingredient label names. Under FDA color additive regulations, ingredient labeling can vary considerably and may reference the source crop, a purified color compound, a processed form of the crop, or, in some cases, be labeled simply as fruit or vegetable juice.
The objective of this report was to evaluate the supply chain considerations and transition challenges associated with incorporating non-FD&C colorants into food products. Organizing the report around active color compounds provided a consistent framework for assessing ingredient sourcing, supply chain risks, technical performance, and the feasibility of reformulation across colorant sources.
As a result, this report is intended to support supply chain and formulation considerations rather than provide regulatory guidance. Users should consult relevant FDA regulations and their legal counsel to determine the appropriate ingredient labeling requirements for specific non-FD&C colorants used in their products.
Crops: Carrots, pumpkin, red palm oil, spinach, apricots, broccoli, and mangoes; the most beta-carotene commercialized in the world is by chemical synthesis from beta-ionone2
International Trade: U.S. beta-carotene imports are concentrated among a few of global trading partners. The United States imports primarily from China (18.0%) and Indonesia (16.0%), followed by India (11.0%) and France (9.0%).
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADI not specified4
European Food Safety Authority (EFSA): Approved, no ADI established4
Food and Drug Administration (FDA): Approved for foods generally5
Betalains
Betalains at a Glance
Color: Purple (acidic conditions) to yellow-brown (alkaline conditions)
Alternatives: Potential non-FD&C replacements include cochineal extract/carmine, black and purple carrot (anthocyanins), and grape skin/grape pomace extracts (anthocyanins).35 Precision fermented beetroot red could also be an alternative to betalains extracted from
crops.36; 37 FDA recently announced approval of a fermentation derived beet root red but is now delaying the effective date of approval due to stakeholder objections.38
International Trade: The United States imports betalains primarily from Germany (22.0%), Poland (18.0%), France (14.0%), India (13.0%), China (11.0%), and Türkiye (8.0%).
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADI not specified39
European Food Safety Authority (EFSA): Approved for specified foods39
Food and Drug Administration (FDA): Approved for foods generally40
International Trade: In 2025, Brazil was the leading supplier of annatto to the United States; Mexico ranked as the second-largest supplier. Together, Brazil and Mexico accounted for 53%
of U.S. imports.
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADIs of 0-12 mg/kg bw for bixin and 0-0.6 mg/kg bw for norbixin68
European Food Safety Authority (EFSA): Approved in specified foods, ADIs of 6 mg/kg bodyweight (BW) for bixin and 0.3 mg/
kg bw for norbixin68
Food and Drug Administration (FDA): Approved for foods generally69
Black and Purple Carrot Anthocyanins
Black and Purple Carrot Anthocyanins at a Glance
Color: Red-purple
Crop: Daucus carota ssp. sativus (black or purple carrot)
Alternatives: Potential natural replacements: red cabbage anthocyanins, grape skin or grape pomace extracts
International Trade: In 2025, India and Türkiye were the top two suppliers of black carrot anthocyanins to the United States, accounting for 55% of all U.S. black carrot anthocyanin imports. Other exporters to the United States include China, Spain, and Poland.
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): Pending review87
European Food Safety Authority (EFSA): Approved, in defined food and beverage categories88
Food and Drug Administration (FDA): Approved for foods generally89
Capsanthin
Capsanthin (Carotenoid) At a Glance
Color: Deep red to orange red
Crop: Primarily paprika (Capsicum annuum); also present in ripe fruits of Maclura tricuspidata, which contain unusual keto carotenoids such as cryptocapsin.
International Trade: The United States imports capsanthin primarily from China (31.0%) and India (27.0%), followed by Spain (18.0%), Mexico (8.0%), Peru (4.0%), and Türkiye (4.0%).
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADI for paprika extract of 0–1.5 mg/kg bw of total carotenoids94
European Food Safety Authority (EFSA): Approved, ADI of 24 mg/kg bw/day or 1.7 mg carotenoids/kg bw/day for paprika extract94
Food and Drug Administration (FDA): Approved for foods generally95
Carmine
Carmine and Cochineal Extract (Anthraquinones) At a Glance
Color: Red
Insect Source: Dactylopius coccus Costa (cochineal insect)
Alternatives: Potential natural replacements: beetroot, capsanthin, lycopene, black and purple carrot
International Trade: Global cochineal production and exports are dominated by Peru. The United States serves as the primary import market, reflecting a highly concentrated supply
chain shaped by specific environmental requirements and strong reliance on a small number of producing countries.
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADI of 0-5 mg/kg bw for carmine106
European Food Safety Authority (EFSA): Approved, ADI of 2.5 mg carminic acid/kg bw/day107
Food and Drug Administration (FDA): Approved for foods generally108
Curcumin
Curcumin at a Glance
Color: Yellow
Crop: Curcuma longa (turmeric rhizome), or turmeric, is the primary source of curcumin, the fourth most used natural colorant in the US by volume and the ninth highest by value
Sourcing: Primarily sourced from India; limited suitability in the United States
International Trade: The U.S. imports curcumin primarily from India (68.0%) and China (10.8%), followed by Bangladesh (7.4%), Myanmar (6.1%), Sri Lanka (4.0%), and Peru (3.6%).
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADI of 0-3 mg/kg bw for curcumin, no ADI for turmeric117; 118
European Food Safety Authority (EFSA): Approved, ADI for curcumin of 3 mg/kg bw/day117; 118
Food and Drug Administration (FDA): Approved for foods generally119
Genipin
Gardenia (Genipin) Blue (Iridoids) At a Glance
Color: Blue (Gardenia Blue)
Crop: Gardenia jasminoides Ellis or jagua
Alternatives: Potential natural replacements: butterfly pea flower and spirulina extract.131
International Trade: The U.S. imports primarily from China (57.0%) and Japan (10.0%), followed by India (8.0%), Vietnam (7.0%), South Korea (5.0%), Indonesia (4.0%), Thailand (3.0%), and the Netherlands (3.0%).
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADI 0-7 mg/kg of body weight per day132
Food and Drug Administration (FDA): Approved as either jagua (genipin-glycine) or gardenia (genipin-soy protein hydrolysate) for specific food and beverage categories133; 134
Alternatives: Potential natural replacements: carmine or cochineal extract, beetroot betalains, red cabbage extract (anthocyanins), beta-carotene148
International Trade: The United States imports lycopene primarily from China (26.0%) and Spain (21.0%), followed by India (18.0%), Italy (12.0%), Brazil (8.0%), and Türkiye (6.0%).11
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADI not specified
European Food Safety Authority (EFSA): Approved, ADI of 0.5 mg/kg body weight (bw) per day149
Food and Drug Administration (FDA): Approved as tomato lycopene extract and tomato lycopene concentrate for use in foods generally150
Alternatives: Potential natural replacements: butterfly pea flower and gardenia (genipin) blue170
International Trade: Global spirulina exports are led by China, followed by India and Ecuador. The United States is the largest import market, reflecting a supply chain dominated by a few
countries with strong production and processing capacity and significant reliance on Chinese supply.11
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): Determined that spirulina extract poses very low toxicological concern at typical use levels but requested additional data on its composition and on potential contaminants,
including microcystins.171
European Food Safety Authority (EFSA): Regulated as a coloring food.172
Food and Drug Administration (FDA): Approved for some food categories,173 proposed expansion of approval is delayed.38
Red Cabbage Anthocyanins
Red Cabbage (Anthocyanins) at a Glance
Color: Red in acidic systems, shifting to purple/blue at higher pH46
Crop: Red cabbage (Brassica oleracea var. capitata rubra)
Alternatives: Potential natural replacements: beetroot (betalains), black and purple carrot (anthocyanins), and grape skin/grape pomace extracts (anthocyanins)
International Trade: The United States imports red cabbage anthocyanins primarily from China (26.0%) and Germany (15.0%), followed by the Netherlands (13.0%), Poland (11.0%), France
(9.0%), and India (8.0%).
Global Regulatory Approval:
European Food Safety Authority (EFSA): Approved as an accepted vegetable source under anthocyanins extracted by aqueous processes from edible fruits and vegetables.203
Food and Drug Administration (FDA): Red cabbage-derived anthocyanins are used in foods generally via vegetable juice color approvals.204
Crops: Carrots, pumpkin, red palm oil, spinach, apricots, broccoli, and mangoes; the most beta-carotene commercialized in the world is by chemical synthesis from beta-ionone2
International Trade: U.S. beta-carotene imports are concentrated among a few of global trading partners. The United States imports primarily from China (18.0%) and Indonesia (16.0%), followed by India (11.0%) and France (9.0%).
Global Regulatory Approval:
Joint FAO/WHO Expert Committee on Food Additives (JECFA): ADI not specified4
European Food Safety Authority (EFSA): Approved, no ADI established4
Food and Drug Administration (FDA): Approved for foods generally5
Consumer demand for ingredient transparency, retailer initiatives, evolving federal priorities, and state-level policy proposals have increased interest in non-FD&C colorants and encouraged companies to evaluate alternatives.
Non-FD&C colorants are food colorants that are not certified FD&C dyes. They can be derived from sources such as fruits, vegetables, spices, algae, and other naturally sourced ingredients. Examples include annatto, turmeric, beet-based colors, paprika, and spirulina.
Not always. Colorants are rarely a one-to-one replacement. Reformulation often requires testing to ensure products maintain their desired appearance, flavor, stability, shelf life, and manufacturing performance.
Many non-FD&C colorants are already used successfully today, but a rapid industry-wide transition could create challenges related to agricultural production, processing capacity, sourcing, and imports. Additional investment and time may be needed to scale supply.
Potential challenges include higher ingredient costs, increased import reliance, agricultural and processing constraints, reformulation timelines, inventory management considerations, and the need for greater coordination across the supply chain.
While many food categories use colorants, confectionery and beverage products are among the most color-dependent categories and may face some of the most significant reformulation and supply chain considerations.
Clear, consistent regulations and realistic implementation timelines can help provide certainty for investment, reformulation planning, agricultural production, and supply chain development.
Retailers can work closely with manufacturers and suppliers to understand timelines, manage inventory transitions, educate store teams, and support consumer awareness as products evolve.
Some products may have slight differences in color appearance due to the unique characteristics of non-FD&C colorants. Companies will work to maintain product quality and consumer expectations throughout any transition.
Success will depend on collaboration across the supply chain, including policymakers, farmers, ingredient suppliers, manufacturers, distributors, and retailers. Regulatory certainty, realistic timelines, supply chain investment, and coordinated planning are all important factors.
