California Food Safety Laws: Recent Changes and Impact

California Food Safety Laws: What Recent Additive, School Food, and Date Labeling Rules Mean for the Food Industry

California Food Safety Act (AB 418)

The California Food Safety Act, also known as Assembly Bill 418, prohibits the manufacture, sale, delivery, distribution, or offering for sale of foods containing four specified substances:

• Brominated vegetable oil
• Potassium bromate
• Propylparaben
• Red Dye No. 3

The prohibition takes effect January 1, 2027. Violations may result in civil penalties of up to $5,000 for a first violation and up to $10,000 for subsequent violations.

Impact on industry

The law may affect baked goods, candies, beverages, frostings, snack foods, and other products that have historically used these ingredients as colors, preservatives, dough conditioners, or stabilizers.

California School Food Safety Act (AB 2316)

The California School Food Safety Act, or AB 2316, applies specifically to foods served or sold in California public schools. Beginning December 31, 2027, covered school foods may not contain:

• Blue 1
• Blue 2
• Green 3
• Red 40
• Yellow 5
• Yellow 6

The restrictions apply to qualifying school breakfasts, lunches, competitive foods, and certain entrées. Foods supplied through the USDA Foods in Schools program are excluded from some provisions. The law does not create a general prohibition on these dyes in foods sold through grocery stores or other retail channels.

Impact on industry

Companies supplying school districts may need to distinguish between products intended for general retail sale and products intended for school food service. Ingredient specifications, certificates of analysis, supplier statements, and product formulation records may be needed to confirm that school products meet the applicable requirements.



Color removal can also affect more than appearance. A replacement color may interact differently with product pH, processing temperature, light exposure, packaging, or storage conditions. Reformulated products may therefore require additional color stability, shelf-life, sensory, or packaging evaluation.

Ultra-Processed Foods in Schools (AB 1264)

California expanded its school food requirements through AB 1264, known as the Real Food, Healthy Kids Act. The law was approved in October 2025 and establishes a regulatory framework for identifying and phasing out certain ultra-processed foods from schools.

Key Deadlines

• June 1, 2028: California Department of Public Health must adopt regulations defining “ultra-processed foods of concern” and “restricted school foods.”
• July 1, 2029: California schools must begin phasing out foods identified under these definitions.
• July 1, 2032: Vendors may no longer offer designated restricted or ultra-processed foods of concern to schools.

Impact on industry

The law does not prohibit every packaged or processed food. Instead, it creates a process for identifying categories of concern through future regulations. Product status may depend on both formulation and processing characteristics, making ingredient documentation and supplier transparency especially important.

Companies selling products to California schools should follow the regulatory process closely. Food that is acceptable under current standards may be affected once the state publishes its definitions and lists of restricted products or ingredients.

Standardized Food Date Label (AB 660)

California’s standardized food date labeling law, AB 660, applies to food manufactured on or after July 1, 2026. When a food displays a date to communicate quality or safety, the label must use one of the state’s approved terms.

For quality dates, the approved language is:

• “BEST if Used by”
• “BEST if Used or Frozen by”

For safety dates, the approved language is:

• “USE by”
• “USE by or Freeze by”

Abbreviated terms may be permitted on small packages and certain beverages. Consumer-facing “sell by” language is prohibited, although coded stock-rotation information that is not easily understood by consumers may still be used internally. The law does not require every food to display a date label when one is not otherwise required.



Impact on industry

The changes are intended to distinguish dates related to product quality from dates related to food safety. This distinction is especially important when determining whether a date represents expected changes in flavor, texture, color, or nutrient content or a point after which the food may present a safety concern.

Before revising date terminology, companies should confirm that the assigned date is supported by an appropriate shelf-life study. Simply changing “Best By” to “Use By,” for example, could change the meaning communicated to the consumer.

Food Additive Safey and Transparency Act (AB 2034)

AB 2034, the Food Additive Safety and Transparency Act, was introduced during California’s 2025–2026 legislative session.

This bill has not yet become law, but it is one of California's most closely watched food proposals.

If enacted, it would:

• Create California's own review system for food additives.
• Prevent additives shown to cause cancer from being treated as safe.
• Require public disclosure and notification for new food additives.
• Increase transparency around ingredients such as flavors, colors, and dietary ingredients.

Because the bill remains pending, its language, exemptions, deadlines, and compliance responsibilities may still change. Companies should avoid treating the current provisions as final requirements, but the proposal provides an indication of the direction California food additive policy may take.

What these laws mean for food manufacturers

For companies like RL Labs' clients, the biggest compliance issues are:

Why Do California Food Laws Affect Products Sold Nationwide?

California’s market size can make state-specific production impractical. Maintaining separate ingredient systems, production schedules, inventory, packaging, and distribution channels may increase complexity and the potential for errors.

For that reason, some companies apply California requirements to products distributed nationally. California’s additive, school food, and labeling laws may therefore influence formulation and packaging decisions even when a product is sold primarily outside the state.

The recent laws also demonstrate that food compliance is no longer limited to federal FDA or USDA requirements. State rules may address specific ingredients, product categories, labeling language, or distribution channels more directly than federal regulations.

Food companies selling in multiple states may need a regulatory review process that evaluates federal requirements alongside state-specific restrictions. Early ingredient review, accurate analytical testing, supported shelf-life dating, and complete supplier documentation can help identify potential compliance concerns before a product reaches the market.

References

California Legislative Information. AB 418 – California Food Safety Act
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB418

California Legislative Information. AB 2316 – California School Food Safety Act
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB2316

California Legislative Information. AB 1264 – Real Food, Healthy Kids Act
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB1264

California Legislative Information. AB 660 – Food and Beverage Date Labeling
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB660

California Legislative Information. AB 2034 – Food Safety, Unsafe Additives, and Ingredient Disclosures
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB2034

U.S. Food and Drug Administration. Brominated Vegetable Oil (BVO)
https://www.fda.gov/food/food-additives-petitions/brominated-vegetable-oil-bvo



U.S. Food and Drug Administration. FDA Revokes Authorization for FD&C Red No. 3
https://www.fda.gov/food/hfp-constituent-updates/fda-revoke-authorization-use-red-no-3-food-and-ingested-drugs