As Donald Trump is set to return to the White House in 2025, regulatory changes and funding challenges could upend the current regulatory priorities affecting the food industry.
The Food and Drug Administration’s (FDA) existing goals – outlined in the 2025 priorities established by the recently launched Human Foods Program – could soon be replaced by a very different approach to food regulation. Plans outlined in the conservative playbook Project 2025, and the likely influential role for Robert F. Kennedy Jr., whom Trump has indicated will have significant control over health and food safety policy, are likely to further complicate the direction for agencies like the FDA.
Policies affecting food safety, labelling, and ingredient regulation could shift significantly depending on which priorities gain traction and whether the FDA can secure the resources to meet its surviving 2025 objectives.
Trump’s first term was marked by significant deregulation across food safety and nutrition, and these priorities may re-emerge in his second administration. In his previous tenure, the FDA’s food safety enforcement declined, with warning letters – one of the agency’s main tools for preventing unsafe products from entering the market – dropping by nearly 37%. The administration also rejected petitions to ban harmful chemicals, such as perchlorate, despite health risks linked to developmental harm, and took a limited approach to addressing PFAS in food packaging.
Trump’s policies extended to school nutrition standards, where his administration rolled back elements of the Healthy, Hunger-Free Kids Act, a programme aimed at improving school meal nutrition. Limits on sodium were relaxed, whole grain requirements were reduced, and flavoured milk was reintroduced. These actions reflect a broader trend of reducing federal involvement in food safety and nutrition, suggesting that the new administration may prioritise industry flexibility over strict regulatory oversight, potentially putting HFP initiatives at risk.
To understand the likely direction of food policy under Trump, Project 2025 – a policy guide by conservative think tank the Heritage Foundation – provides valuable insights. Known for its strong ties to the Republican party leadership, the Heritage Foundation has outlined an agenda that promotes reduced government intervention in various sectors, including food safety and agriculture. Project 2025 aligns closely with Trump’s previous deregulatory approach, and its recommendations could significantly shape his administration’s food policy.
A primary proposal within Project 2025 is the repeal of the federal Dietary Guidelines, which currently shape nutrition policy for federal programmes like school meals and the Supplemental Nutrition Assistance Program (SNAP). The playbook argues that nutritional guidance is better managed by private health providers than by federal authorities. Removing the Dietary Guidelines would signal a major reduction in federal involvement in public health nutrition.
The document also advocates for repealing the mandatory labelling requirement for genetically engineered foods, instead recommending a voluntary approach. Project 2025 frames federal labelling requirements as regulatory burdens that stymie agricultural innovation, particularly in biotechnology. If adopted, these policies would prioritise industry-led standards over FDA-driven regulation, posing potential conflicts with the HFP’s consumer-focused goals.
While Project 2025 and Trump’s past policies reflect a deregulatory stance, Robert F. Kennedy Jr. is expected to bring a contrasting perspective to food policy in some respects. Trump has indicated that Kennedy, a prominent figure throughout his campaign, will have substantial influence in health and food safety policy, possibly in an advisory role with significant oversight powers. Kennedy’s advocacy, which at times diverges sharply from Project 2025’s principles, may bring a different agenda to Trump’s conservative framework.
Under the slogan ‘Make America Healthy Again’, Kennedy has publicly championed efforts to restrict ultra-processed foods, seed oils, and pesticides, arguing that these products contribute to chronic disease. He has also been a vocal opponent of genetically engineered foods, pushing for tighter regulations on genetically engineered (GE) ingredients and reduced reliance on pesticides, which he argues have not been sufficiently evaluated for safety. His approach conflicts with Project 2025’s emphasis on promoting biotechnology and reducing oversight, reflecting his focus on ingredient safety and public health.
Kennedy has also criticised what he views as an FDA bias towards pharmaceutical and food industry interests, contending that these relationships hinder public health protections. On the day after the election, RFK Jr. told the broadcaster MSNBC: “In some categories, there are entire departments, like the nutrition department at the FDA that are – that have to go, that are not doing their job, they're not protecting our kids.”
The FDA’s Human Foods Program (HFP) was launched only weeks before the election, on 1 October 2024, with the aim of centralising and modernising oversight of food safety, nutrition, and chemical regulations. In early November, the HFP released its 2025 priorities, which focused on food chemical safety, labelling transparency, and streamlined reviews of new ingredients.
The FDA’s HFP places a priority on ensuring that the presence of chemicals in food – whether through ingredients, processing aids, or contaminants – remains within safe limits.
Without sufficient federal funding and with many chemicals not yet officially designated as harmful by the agency, individual states also play a critical role in food safety. “The dysfunction at the federal level is driving individual states to step in as the regulators of last resort for US consumers,” Sarah Sorscher, director of regulatory affairs at the Center for Science in the Public Interest (CSPI), told Fi Global Insights. She noted that states like California and New York have already banned dangerous additives, including Red 3, and that New York has recently expanded its list of restricted chemicals to include titanium dioxide.
Should federal oversight weaken further under the incoming Trump administration, the trend toward state-led regulation could intensify, leading to inconsistencies across the national food safety landscape.
The HFP’s plans for 2025 also include the introduction of mandatory front-of-package (FOP) labelling. This proposal would require clear labelling on products high in sodium, saturated fat, and added sugars, aiming to improve transparency and help consumers make more informed choices.
Given the Trump administration’s apparent preference for market-led solutions, this labelling initiative may face resistance under the new government.
Another key component of the HFP’s priorities is the improvement of pre-market review processes for food additives, colourants, food contact substances, and substances labelled as Generally Recognized as Safe (GRAS). The FDA aims to streamline these processes to prevent unsafe uses of chemicals and ensure that new food ingredients meet safety standards without introducing unnecessary risks. Achieving this will require increased funding to manage the anticipated growth in workload.
Current proposals in Congress seek to close GRAS loophole, which allows companies to self-certify the safety of new food additives without FDA oversight, by mandating FDA oversight.
However, Sorscher stressed that meaningful reform would require significantly more funding to give the FDA the resources to review all the GRAS notices and food additive requests. Without either new federal funding or user fees from the industry to cover review costs, it would be difficult for the FDA to enforce expanded review processes.
Even if elements of the Human Foods Program survive, funding limitations could constrain its implementation. Historically, Republican-led Congresses have reduced funding for public health and nutrition.
“The FDA foods programme has been starved of funding for many years,” Sorscher notes, adding that these cuts have affected the FDA’s ability to partner with states on food safety inspections, which make up approximately 75% of the agency’s inspection efforts. “Three out of every four food safety inspections in the US are conducted through state contracts with the FDA, and funding for these is being cut by a third.”
