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The U.S. Food and Drug Administration announced on May 12, 2026, “two decisive actions focused on food chemical safety.” First, FDA released two final documents for its new proactive food chemical safety post-market assessment program. Second, FDA launched reassessments of butylated hydroxytoluene (BHT) and azodicarbonamide (ADA), “chemical additives commonly used in a variety of food products.” As part of the reassessment, FDA issued two requests for information regarding the use and...

Concerns about microplastics and their effect on human and environmental health are no longer confined to academic literature or environmental advocacy. On April 6, 2026, the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Health and Human Services (HHS) elevated the issue in a way that makes it harder for the regulated community to address the issue of microplastics as largely academic or purely speculative. EPA has proposed to add microplastics, for the first time, as a...

On May 6, 2026, the National Agricultural Law Center (NALC) and the National Association of State Departments of Agriculture (NASDA) Foundation will host a half-day program featuring the latest updates in agricultural and food law policy from experts across the country in Washington, D.C. The agenda includes: “Four Corners” Congressional Update: Ag Trade, E-15, MAHA, Farm Bill, and Related Issues: Fitzhugh Elder IV, Staff Director, Senate Committee on Agriculture, Nutrition, and Forestry;...

The U.S. Food and Drug Administration’s (FDA) Human Food Program (HFP) has prepared a list of priority research, data, and method needs that, if fulfilled, will help FDA better understand the underlying factors that may cause or contribute to health risks from HFP-regulated products. FDA states that it provided these research, data, and method needs for researchers interested in pursuing science that is useful to advancing the safety of the U.S. food supply. According to FDA, the list may also...

As required under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), on December 29, 2025, the U.S. Food and Drug Administration (FDA) published a Report on the Use of PFAS in Cosmetic Products and Associated Risks. The scope of the report is limited to per- and polyfluoroalkyl substances (PFAS) intentionally added to cosmetic products as ingredients and does not include PFAS that may be present in the final product as contaminants. According to the report, “[c]ertain PFAS are...

Download a PDF of the Forecast 2026. Bergeson & Campbell, P.C. (B&C®), its global consulting affiliate The Acta Group (Acta®), and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are pleased to share with you our Forecast 2026. Our distinguished global team of chemical experts worked hard to summarize our collective best guess on what to expect in the New Year regarding global industrial, agricultural, and biocidal chemical regulatory and policy...

As 2025 draws to a close, one of the most consequential, but least publicly discussed, shifts in federal environmental governance has been the quiet expansion of artificial intelligence (AI) behind the scenes across multiple federal agencies. AI tools are not new in federal science programs, but 2025 marked a turning point: agencies began integrating machine-learning models into routine workflows in exposure modeling, surveillance, enforcement targeting, and environmental monitoring. The White...

On May 22, 2025, the U.S. Department of Health and Human Services (HHS) announced the release of a new federal report, Making Our Children Healthy Again (MAHA Assessment) issued by the Make America Healthy Again (MAHA) Commission. The MAHA Commission was established by Executive Order (EO) 14212 to: (a) study the scope of the childhood chronic disease crisis and any potential contributing causes, including the American diet, absorption of toxic material, medical treatments, lifestyle,...

In response to President Trump’s February 13, 2025, Executive Order (EO) 14212, “Establishing The President’s Make America Healthy Again Commission,” the White House issued part of what is being called “The MAHA Report” (with MAHA an acronym for Make America Healthy Again), entitled “Make Our Children Healthy Again: Assessment” (the Assessment) on May 22, 2025. Section One of the Assessment, “The Shift to Ultra-Processed Foods,” includes the Commission’s thoughts on the...

Ponder the following existential question: Who does their job less effectively? Members of Congress, or employees of federal agencies? Let’s examine the U.S. Environmental Protection Agency (EPA) employees versus those responsible for legislating environmental laws. Congress has not been able to reauthorize environmental statutes for years, with some (most) needing significant attention. EPA relies on 1990 Clean Air Act amendments to sort out air pollution issues and address climate change...

Bergeson & Campbell, P.C. (B&C®), its global consulting affiliate The Acta Group (Acta®), and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are pleased to share with you our 2025 Forecast. For all the reasons you might imagine, our seasoned team was especially challenged this year in speculating on what to expect in 2025 regarding global industrial, agricultural, and biocidal chemical regulatory and policy initiatives. Given the European Parliamentary...

Download transcript. This week I had the pleasure of speaking with U.S. Food and Drug Administration (FDA) Deputy Commissioner for Human Foods, Jim Jones, about all the amazing initiatives Jim is overseeing as the first FDA Deputy Commissioner for Human Foods. Many of us in the chemical community know Jim and his extraordinary career at the U.S. Environmental Protection Agency (EPA) leading both the EPA pesticides and toxics program offices, culminating his EPA career as Assistant Administrator...

The Physicians Committee for Responsible Medicine (PCRM) New Approach Methodologies (NAM) Use for Regulatory Application (NURA) program will hold a series of webinars on human-based methods in U.S. Food and Drug Administration (FDA) submissions. PCRM notes that traditionally, submissions have included data from animal studies, but industry has started submitting NAMs. According to PCRM, the use of NAMs in FDA submissions is expected to grow, as many toxicologists seek to use human-based...

As reported in our August 7, 2024, blog item, the U.S. Food and Drug Administration (FDA) announced on August 1, 2024, that it will hold a public meeting on September 25, 2024, on the development of an enhanced systematic process for its post-market assessment of chemicals in food. 89 Fed. Reg. 65633. FDA has posted a Discussion Paper Development of an Enhanced Systematic Process for the FDA’s Post-Market Assessment of Chemicals in Food (Discussion Paper). The Discussion Paper “broadly...

The U.S. Food and Drug Administration (FDA), the primary federal agency committed to safe exposure to chemicals in the food supply, has recently stepped up efforts to ensure food safety, especially in the post-market assessment area. Stakeholders in commercial chemical operations and product lines involving chemicals used for or found in the food supply should be prepared for increased inspections and enforcement in this area. Chemicals in Food The Federal Food, Drug, and Cosmetic Act (FFDCA)...

On May 8, 2024, the U.S. Environmental Protection Agency (EPA), U.S. Food and Drug Administration (FDA), and the U.S. Department of Agriculture (USDA) released a plan to update, streamline, and clarify their regulations and oversight mechanisms for products of biotechnology. The Coordinated Framework for the Regulation of Biotechnology: Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology (the Plan) provides a roadmap for actions the agencies will take,...

The U.S. Food and Drug Administration (FDA) announced on April 5, 2024, the results of its 2023 sampling assignment, testing talc-containing cosmetic products for the presence of asbestos. The testing was conducted using Polarized Light Microscopy (PLM) and Transmission Electron Microscopy (TEM). FDA states that “[a]sbestos was not detected in any of the 50 samples tested in 2023.” FDA states that it selected and purchased cosmetic products, and then it blinded and transferred the samples to...

The U.S. Food and Drug Administration (FDA) issued a Constituent Update on March 4, 2024, that updates its “List of Select Chemicals in the Food Supply Under FDA Review.” FDA states that the intent of this update is “…to provide more insight on the status of the FDA’s post-market assessments of chemicals in the food supply.” The information posted today includes many chemicals that FDA has been actively engaged in reviewing for the past several years. The Update also explains the...

The U.S. Food and Drug Administration (FDA) has posted a February 2024 guidance entitled “Foods Derived from Plants Produced Using Genome Editing: Guidance for Industry.” According to FDA, one purpose of the guidance is to clarify how its 1992 policy statement “Statement of Policy: Foods Derived from New Plant Varieties” (NPV policy) (57 Fed. Reg. 22984) applies to foods derived from NPVs produced using genome editing. The NPV policy provides scientific and regulatory guidance on foods...