From Backlog to Breakthrough: Rethinking How FDA Reviews Food Chemicals

January 5, 2026

The food we eat every day contains thousands of added chemicals. Many of these chemicals entered the U.S. food supply decades ago and have never been independently reviewed by the government. Recently, the U.S. Food and Drug Administration (FDA) took an important step toward addressing this gap by proposing a new tool to help prioritize which food chemicals should be reviewed first. FoodFight USA submitted a public comment on this proposal.

You can read FDA’s proposal for a prioritization tool and our response below. And if you want to join the fight and learn more about opportunities to clean up America’s food system, please sign up for our newsletter.

📄 Read FDA’s Proposed Prioritization Tool for Post-Market Assessment of Food Chemicals (PDF)
📄Read FoodFight USA’s full public comment (PDF)

Why Post-Market Review of Food Chemicals Matters

GRAS (Generally Recognized As Safe) is uniquely American – it has no equivalent in any other country. This decades-old framework has allowed companies to self-regulate and introduce chemical additives into our food supply without pre-market government oversight, resulting in more than 10,000 additives entering the U.S. food supply.

The real number may be even higher. We don’t even know the names of many of these additives because companies exploiting the loophole can hire their own scientists to declare them as “safe” without submitting to the FDA at all. Since 2000, an estimated 99% of chemicals added to the U.S. food supply have been declared safe only by the companies selling them, with no disclosure to the FDA.

Closing the GRAS loophole for new chemicals would be a positive step, but it would not address the thousands of additives already in circulation. Former FDA officials have acknowledged that it would take one year and $1 million per chemical to properly assess safety. Reviewing these chemicals one by one using traditional methods could take years per chemical – far too slow to protect public health.

What FDA is Proposing

FDA’s proposed Post-Market Assessment Prioritization Tool is designed to help the agency decide which food chemicals should be reviewed first. Rather than assessing every chemical at once, the tool ranks them based on potential public health risk and other factors. It considers:

  • Potential health harms, such as links to cancer or developmental effects
  • How much people are exposed, and whether exposure has increased
  • Impacts on vulnerable populations, like infants and children
  • New scientific evidence that could change previous safety conclusions
  • Public and regulatory concern, including actions taken by other governments

This structured, data-driven approach is an improvement over ad hoc decision-making and a reactive system in which FDA has typically conducted post-market reviews only after overwhelming public pressure for specific chemicals. FoodFight USA supports FDA’s goal of making chemical review more systematic, transparent, and science-driven.

Where FDA’s Proposal Falls Short

While the prioritization tool is a step in the right direction, speed and scale remain our central concern. As proposed, FDA staff and subject-matter experts would still need to manually review information and score each of the 10,000+ chemicals just to determine priority. That process risks becoming yet another slow, resource-intensive bottleneck, delaying action on chemicals that may already pose serious risks. The tool adds a new step, but does not solve the underlying problem: our current system moves far too slowly to keep up with modern food risks.

In our submission, we emphasize that:

  • Heavy reliance on qualitative judgment can introduce subjectivity.
  • International regulatory actions (such as bans in the EU, Canada, Japan) should trigger faster U.S. review.
  • Public confidence matters, but science-based risk should drive decisions.

A Better Way Forward: Combining Prioritization and Action

We believe that prioritization should not be separate from assessment – they should happen together. Modern tools now make this possible. At FoodFight USA, one of our cornerstone initiatives is a Post-Market GRAS AI Analysis: an AI-enabled approach designed to evaluate thousands of food chemicals in weeks, not years.

Our approach:

  • Leverages existing federal and international datasets already funded by taxpayers
  • Uses advanced computational toxicology and machine learning tools
  • Groups chemicals by structural similarity to identify harmful classes faster
  • Focuses first on chemicals that are both widely used and most likely to cause harm

With this approach, we can generate a prioritized shortlist of the GRAS chemicals and chemical classes of highest concern, giving regulators a clear place to start.

Additionally, faster post-market action does not have to start from scratch. A recent example is former FDA Commissioner Dr. David Kessler’s petition urging FDA to revoke the GRAS status of refined carbohydrates used in ultra-processed foods. Rather than evaluating individual chemicals one by one, the petition calls on FDA to review an entire ingredient category whose safety assumptions no longer reflect modern levels of exposure. This category-based approach offers a clear, legally grounded pathway for accelerating post-market review and avoiding years of delay. Approaches like this, combined with data-driven prioritization and modern analytical tools, can help FDA move beyond reactive, chemical-by-chemical reviews and toward a faster, more protective food safety system.

Working Together to Accelerate Food Safety

Our public comment is not a rejection of FDA’s proposal, but an invitation to strengthen it. We are actively collaborating with leading academic institutions and researchers in toxicology, cheminformatics, and AI-driven risk assessment, and we stand ready to work with FDA.

Our shared goal is simple: a food safety system that moves at the speed of science, not bureaucracy.

Americans should not have to wait years to find out whether a chemical in their food is unsafe. With modern tools and smarter processes, we can protect public health faster and restore trust in the safety of our food supply.

To stay updated on post-market chemical review efforts, future FDA actions, and our work to improve the safety and transparency of America’s food system, subscribe to the FoodFight USA newsletter.

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