Your formula is approved. Your holiday run is on the calendar. Then two dates land on your desk in the same week. One is a federal deadline for Red No. 3. The other is a customer who wants certified colors gone from every product. Both dates matter, and they do not match.
Here are both clocks, a way to map them to your SKUs, and what to ask for before you change a single color.
Clock One: Red No. 3 Has a Hard Date
The FDA revoked its authorization for FD&C Red No. 3 in January 2025. Food makers must remove it by January 15, 2027. The FDA states this on its industry pledge tracker and encourages companies to act before that date.
California adds a second date. Its restriction takes effect January 1, 2027, two weeks before the federal deadline, according to the PolicyCanary food dye tracker. If you ship into California, plan to the earlier date.
Of the dyes in common use, Red No. 3 is the only one with a binding federal date. Treat it as a hard stop, not a goal.
Clock Two: Six Dyes and a Later Goal
The same FDA page lists six remaining certified colors: FD&C Green No. 3, Red No. 40, Yellow No. 5, Yellow No. 6, Blue No. 1, and Blue No. 2. The FDA says it is working with industry to eliminate them by the end of 2027. This is a joint effort, not a rule.
Do not treat that date as your deadline. Many customers set their own, and some set earlier ones. The FDA tracker lists these pledges:
- Walmart plans to finish removing certified colors from its private brand foods in January 2027.
- Grupo Bimbo set the end of 2026 for its entire portfolio.
- WK Kellogg set the end of 2026 for existing products.
- Kraft Heinz, The Hershey Company, and McKee Foods set the end of 2027.
- The American Bakers Association pledged to remove certified colors from baked goods sold to K through 12 schools by the 2026 to 2027 school year, and from baked goods across the United States by December 2028.
Your own customers matter more than any list. Ask each one which date they hold you to, and write it down.
Map Every SKU to a Clock
You do not need a new system. You need one table. Build it this week.
- List every SKU that uses a certified color, by dye name.
- Mark each SKU that uses Red No. 3. Those move first.
- Add the customer date for each SKU.
- Add the ship season. Holiday items go before everyday items.
- Add an owner and a test date to each row.
Sort the table by the earliest date. The top rows are your plan.
Read the Ingredient Deck Before the Brochure
A good packet names every color source. Take FoodGrid’s information packet for Natural Rainbow Sprinkles, 8 Color Vibrant Blend. Its ingredient statement lists sugar, palm kernel and palm oil, corn starch, vegetable juice, sunflower lecithin, annatto extract, beet juice, spirulina extract, turmeric, beta carotene, paprika oleoresin, maltodextrin, carnauba wax, and cellulose gum.
The Christmas Blend Nonpareils packet is shorter. It lists sugar, corn starch, beta carotene, vegetable juice, spirulina extract, and carnauba wax.
A packet holds more than an ingredient list. The sprinkles packet has 13 sections: product specifications, a nutritional data sheet, an allergen declaration, kosher, non-GMO, gluten-free, and soy-free declarations, a partially hydrogenated oil statement, a vegan statement, a Proposition 65 statement, a letter of guarantee, a food defense statement, and a bioterrorism preparedness statement.
The specifications set moisture below 5 percent and list limits for yeast, mold, and pathogens. Shelf life is 15 months from manufacture when the product stays cool, dark, and sealed.
Ask every supplier for a packet like this before your first trial. If a supplier cannot send one, you have your answer.
Why Reds and Pinks Need Their Own Trial
Reds and pinks take the most reformulation time. Red No. 3 sits in that family, and so do many shades buyers expect on holiday items. Natural reds and pinks often come from sources such as beet juice, and each source reacts to heat, light, and moisture in its own way. The FDA has also approved new natural options, including beetroot red, gardenia blue, butterfly pea flower extract, Galdieria extract blue, and calcium phosphate.
Start with the shade. Match it under the same light your customer uses. A color that looks right on a bench can look different on a shelf. Then check how it holds. Bake it, cool it, wrap it, and store it. Look again after a week and again after a month.
Next, check the process. Heat, moisture, and the surface all change how a natural color behaves. A sprinkle on wet icing is a different test from a sprinkle on a dry cookie. Run the test that matches your real product.
Keep notes on every trial: the lot number, the date, and the result. If a shade drifts later, those notes tell you where to look first.
Three Questions for Every Holiday Color
Holiday runs leave little room for a second try. Before you approve a color for Thanksgiving or Christmas, ask:
- Does the color match your standard on the day it arrives?
- Does it still match after storage?
- Does the packet match your label?
FoodGrid’s Natural Sprinkles Seasonal Blends come in Rainbow, Holiday, and Seasonal formulations, including Thanksgiving and Christmas blends. The product page lists them as made with natural colors, soy-free, nut-free, dairy-free, and gluten-free, with no artificial preservatives and no hydrogenation. If you need one shade at a time, see the natural individual colored sprinkles.
Buyers looking for a clean label ingredients distributor want proof they can file. Ask your supplier to send the declarations with the first quote, not after the order.
What to Tell Your Retail Buyer
Buyers do not like surprises. Tell them early which products change and when. Send the new ingredient statement as soon as it is final.
Watch your label claims. The FDA tracker says the agency updated its labeling policy to give companies more room for “no artificial colors” claims when they use naturally derived colors. That does not make every claim safe. Ask your regulatory contact to review each one before you print.
Share your documents too. A buyer who sees an allergen declaration, a kosher statement, and a letter of guarantee on day one asks fewer follow-up questions. That saves days on both sides.
Keep Old and New Colors Apart
A color change creates a hidden risk on the production floor. Old stock and new stock can end up in the same room. Set a clear cutover date for each SKU.
- Label every lot of old color and new color.
- Use up or return old stock before the new color goes live.
- Check packaging stock, because old film and cartons may carry the old ingredient statement.
- Update your lot tracking so you can trace any shipment.
These steps cost little. A mixed shipment can cost you a customer and trigger a recall review.
What Is Still Unsettled
Some questions remain open, so plan for change. The FDA finalized the revocation of Orange B and proposed to revoke Citrus Red No. 2. Neither is common in bakery work, but both show the agency is still acting.
The six-dye effort has no federal rule behind it. Several states have passed their own dye laws, and the details differ. Check each state where you ship, and ask your regulatory contact which rules apply to each SKU.
Build slack into your plan. If a date moves earlier, you want a finished trial in hand. If it moves later, you lose nothing.
Who Signs Off on a Color Change
A color change touches more teams than R&D. Name each reviewer early, and give each one a clear question.
- R&D checks shade, process fit, and shelf stability.
- Quality checks the spec, the certificate of analysis, and the allergen statement.
- Regulatory checks the label and any claim on the package.
- Procurement checks price, lead time, and how long the quote holds.
- Operations checks line time, cleaning steps, and cutover dates.
- Sales tells each customer what is changing and when.
Put the sign-offs on one page. A change that skips a reviewer tends to come back as rework.
A Four Week Plan
- Week one: Build the SKU table and confirm each customer date.
- Week two: Request packets and samples for every red and pink item.
- Week three: Run bench trials, then a short plant trial.
- Week four: Check color after storage and review label copy with your regulatory contact.
Give each row one owner. A row with two owners often has none. Meet for fifteen minutes each week and ask what is done, what is late, and what you need from another team.
Why Waiting Costs More
Neither clock is a surprise. The Red No. 3 date has been public since January 2025, and customer pledges are posted for anyone to read. The risk comes from treating them as one date, or from waiting until December to test.
Teams that test in November have time to fix a shade, reorder, and reprint a label. A failed trial in December can push a holiday SKU past its ship date, and your sales team absorbs that cost. The work is small: one table, a few sample requests, and a storage check.
The FDA updates its tracker as companies report, so check the live page before you sign anything.
Request a Sample Today
FoodGrid supplies natural sprinkles and nonpareils with full documentation packets. Request a sample or contact our ingredient team to plan your holiday and Q1 runs.
Real Ingredients. Smarter Solutions.
