2025 has been a landmark year in the realm of food law and policy, with significant developments that are reshaping the landscape of how we produce, consume, and regulate food. The Make America Healthy Again (MAHA) movement, which emerged from obscurity in 2024, has become a central theme in food law this year. On February 13, 2025, President Trump signed an Executive Order establishing the MAHA Commission, tasked with addressing the childhood chronic disease crisis. The Commission’s subsequent reports, The MAHA Report and The MAHA Strategy, identified four primary drivers of childhood chronic diseases and outlined strategies to tackle them. This initiative, spearheaded by Health and Human Services Secretary Robert Kennedy, has spurred notable changes at both federal and state levels.
One of the most significant areas of focus has been the definition and regulation of ultra-processed foods (UPFs). Currently, there is no universally accepted definition of UPFs in law or science. However, California’s AB 1264, passed in 2025, created the first statutory definition of UPFs and banned certain foods meeting that definition from being served in schools. This move is particularly noteworthy as the US Department of Agriculture (USDA) and the Food and Drug Administration (FDA) announced a collaboration to create a federally recognized uniform definition for UPFs. The agencies published a joint Request for Information seeking public input on their definition. While the federal definition remains uncertain, California’s law could influence other states as they draft their own UPF proposals.
In line with the MAHA movement, several states sought waivers from the USDA to limit the types of foods eligible for purchase with Supplemental Nutrition Assistance Program (SNAP) benefits. While SNAP is a federal program, it is administered through state actors, with the USDA determining eligible foods. To restrict certain foods, states must request permission through a waiver process. In 2025, eighteen states submitted waiver requests, with fifteen being granted so far. These waivers aim to exclude “junk” food from SNAP benefits, reflecting a broader trend towards promoting healthier food choices.
The One Big Beautiful Bill Act (OBBBA), passed in the Fiscal Year 2025 appropriations bill, included several changes to SNAP that will impact participant eligibility. The bill altered the Thrifty Food Plan, which determines SNAP benefit amounts, requiring it to be “cost-neutral” and adjusted only in relation to inflation. This change is likely to reduce SNAP benefits in the future. Additionally, the OBBBA modified work requirements for SNAP participants, required states with high payment error rates to pay an increased share of SNAP benefits, eliminated the Supplemental Nutrition Assistance Program Education (SNAP-Ed), and removed SNAP eligibility for certain non-citizens, such as refugees, who had previously been eligible.
Federal oversight of food ingredients has also been a major theme this year. In January 2025, the Biden Administration’s FDA revoked the color additive listing for Red Dye No. 3 in food and ingested drugs. Following the presidential transition, FDA and HHS Secretary Kennedy continued to focus on food ingredients. FDA announced a six-pronged plan to phase out synthetic dyes, including actions like authorizing new natural color dyes and revoking authority for synthetic dyes Citrus Red No. 2 and Orange B. In response, many food manufacturing companies announced plans to remove synthetic dyes from their products. Concurrently, FDA introduced a new review process for food chemicals already on the market. Secretary Kennedy also directed FDA to explore eliminating the “generally recognized as safe” self-affirming pathway for food ingredients.
State-level MAHA laws have also seen significant developments. Both Texas and Louisiana passed landmark legislation creating labeling requirements for foods containing specific ingredients. Other states have proposed various legislative measures, including bans on artificial food dyes, required disclosures for the presence of seed oils, and mandated reporting for foods made with “GRAS” ingredients.
In December 2024, the Biden Administration’s FDA published a final rule updating the definition for the labeling claim “healthy.” This rule updated the requirements for human food products to bear the claim “healthy” on their packaging. Initially set to take effect on February 25, 2025, the Trump Administration delayed the effective date by 60 days for review. However, the rule took effect on April 28, 2025, without amendments, with a compliance date of February 25, 2028.
Lastly, in April 2025, the USDA’s Food Safety and Inspection Service (FSIS) withdrew its proposed rule entitled “Salmonella Framework for Raw Poultry Products.” The proposal aimed to declare poultry products adulterated if contaminated with certain levels or distinguishable strands of Salmonella