On July 16, 2025, the U.S. Food and Drug Administration (FDA) announced its decision to revoke and propose the revocation of 52 food standards of identity (SOIs). This move aligns with the Trump Administration’s deregulatory initiatives, as outlined in Executive Order 14192, “Unleashing Prosperity Through Deregulation.” The FDA deems these standards obsolete and unnecessary, marking a significant shift in the regulatory landscape of the food industry.
**Understanding Standards of Identity**
SOIs are regulatory measures established to ensure that specific foods meet consumer expectations regarding their characteristics, ingredients, and production processes. The Federal Food, Drug, and Cosmetic Act (FDCA) authorizes the FDA to create these standards to promote honesty and fair dealing in the food industry. Historically, SOIs were crucial in combating economic adulteration, where food companies would substitute expensive ingredients with cheaper alternatives without informing consumers.
For instance, the FDA’s SOI for jam requires that products labeled as “jam” contain a minimum amount of fruit, preventing manufacturers from selling fruit-free products under the same label. Similarly, the USDA, which shares responsibility for food safety, has established approximately 80 standards for meat and poultry products. These standards aim to protect public health and ensure consistency in food labeling and production.
**The Role of SOIs in Food Regulation**
Currently, the FDA has over 250 SOIs published in its regulations, covering a wide range of foods. These standards specify mandatory and optional ingredients, manufacturing requirements, and labeling guidelines. For example, the SOI for milk chocolate requires that it contain at least 3.39% milkfat and 12% total milk solids, distinguishing it from white chocolate, which has different ingredient proportions.
The FDA justifies the revocation of 52 SOIs by asserting that modern regulatory requirements, such as ingredient and nutrition labeling, are more effective in protecting consumers. These labeling requirements ensure that food products bear a “statement of identity” on their principal display panel, which can be the food’s legal name, common or usual name, or a non-misleading descriptive name. This approach aims to provide consumers with accurate information about the products they purchase.
**Enforcement and Implications**
The FDA enforces SOIs through various mechanisms, including warning letters, voluntary recalls, and mandatory recalls. Typically, the agency first notifies manufacturers of violations through warning letters, giving them the opportunity to conduct voluntary recalls. If compliance is not achieved, the FDA may order mandatory recalls, ensuring that problematic foods are removed from the market.
However, the FDA has shown flexibility in enforcing SOIs in certain cases. For example, despite the established SOI for milk, plant-based milk alternatives like soy milk and almond milk are permitted to use the term “milk.” The FDA argues that these products have established common or usual names, and other plant-based alternatives should use non-misleading descriptive names, such as “Cashew Milk.”
**Looking Ahead**
The FDA’s decision to revoke 52 SOIs reflects a broader trend towards deregulation and reliance on modern labeling requirements to protect consumers. While this move may streamline regulatory processes, it also raises questions about the potential for increased economic adulteration and the need for robust enforcement mechanisms.
As the food industry adapts to these changes, stakeholders must remain vigilant in ensuring that consumer trust and product integrity are maintained. The FDA’s ongoing efforts to update and revise SOIs will continue to shape the regulatory landscape, influencing how food products are labeled, manufactured, and marketed in the years to come.