What’s a GRAS Procedure?
The Generally Recognized as Safe (GRAS) procedure is a regulatory framework in the United States that allows substances to be used in food without undergoing the rigorous premarket approval process required for food additives (which is called, instead, Food Additive Petition).
According to the Federal Food, Drug, and Cosmetic Act, a substance can be classified as GRAS if qualified experts consider it safe based on scientific evidence or its historical use in food prior to 1958.
There are two main pathways to obtain GRAS status: through scientific procedures, which demand evidence comparable to that of a food additive petition, and through experience based on common use, which relies on a significant history of consumption. Manufacturers can either self-affirm GRAS status or voluntarily submit a GRAS notice to the Food and Drug Administration (FDA); however, submitting a notice does not mean that the FDA will authorise it, but rather perform a review.
Current Challenges
The current GRAS system has faced criticism for its voluntary nature, allowing manufacturers to exploit the GRAS self-affirmed procedure, thereby bypassing the FDA review. This has raised concerns about potential health risks from unreviewed food substances.
For this reason, the U.S. Secretary of Health and Human Services, Robert F. Kennedy Jr., is putting efforts to reform the FDA’s Generally Recognized as Safe (GRAS) program[1]. Kennedy’s initiative aims to address these concerns by eliminating the self-affirmation process and requiring companies to notify the FDA and provide safety data for new ingredients before they can enter the market, as it was done at the very beginning. This move is intended to enhance consumer protection and restore trust in the nation’s food supply.
Controversial Opinions
While experts support the initiative, they express scepticism about its feasibility due to potential resource constraints at the FDA and resistance from the food industry. Kennedy is actively collaborating with major food companies to develop solutions and enhance transparency, signalling a significant shift in regulatory oversight that could impact innovation in food technology and consumer health.
Potential Consequences of the Reforms
Despite the reforms to the GRAS process aim to enhance transparency over the food chain, these changes may increase regulatory costs and complexity for manufacturers. This could potentially slow the introduction of new ingredients, which might further hinder innovation in the food sector.
It must be said that these difficulties are perceived and experienced in Europe where all food ingredients must be authorised first.
On the other hand, these reforms could alleviate consumer concerns about regulatory oversight and foster greater trust in the safety of their food.
Brighter and darker sides
Companies that determine the GRAS (Generally Recognized as Safe) status of their ingredients by following FDA guidelines are unlikely to face significant or harmful consequences. When the FDA’s scientific approach is properly applied, it ensures a thorough and thoughtful assessment of the substance’s safety. On the other hand, companies that self-determine GRAS status without sufficient scientific rigor may face difficulties obtaining FDA authorization in the future.
Whatever happens, we will always be here to inform you.
For more information, ask Chemsafe.
[1] RFK Jr. wants to eliminate FDA’s controversial food additive program. Here’s why that matters | CNN







