Who Decides What Is Safe to Eat? An Analysis of the FDA's New GRAS Proposal

When you buy a packaged food, you might assume every ingredient has been individually reviewed by the government. In reality, the regulatory process is more complicated.
Some substances added to food are regulated as food additives, which generally require review by the U.S. Food and Drug Administration (FDA) before use. Others can qualify as “Generally Recognized as Safe,” or GRAS, and do not require the same type of FDA premarket approval.
That distinction is at the center of a new FDA proposal announced on August 10, 2026. The proposed rule would require companies to notify the FDA when they determine that certain substances added to food are GRAS. Under the current system, companies can make a GRAS determination without notifying the FDA, although they may voluntarily submit a notice.
The proposal would therefore give the FDA more information about substances companies consider safe for use in food. However, it is important to remember that this is a proposed rule, not a final policy.
Why Does GRAS Matter?
The term GRAS may be unfamiliar to consumers, but it affects how ingredients enter the food supply. The FDA explains that GRAS substances are not subject to premarket approval when used under the conditions for which they are considered safe. Examples include ingredients such as vinegar, canola oil, and black pepper.
The larger policy question is not simply whether an ingredient is “safe” or “unsafe.” It is how safety is determined and how much information regulators and the public receive about those decisions.
Under the proposed rule, the FDA says increased reporting could provide regulators and the public with more information about substances used in human and animal food and the evidence supporting companies’ safety determinations.
Why Have Researchers Raised Concerns?
Researchers have previously examined potential conflicts of interest within the GRAS system. A 2023 study found that financial relationships between manufacturers and experts involved in safety assessments were common among the historical GRAS notifications it reviewed (Neltner et al., 2023). Other researchers have argued that the food safety system could be strengthened by improving how food ingredients are evaluated and monitored (Maffini et al., 2021).
The proposed rule would not eliminate the GRAS category. Instead, it would change how certain GRAS determinations are reported to the FDA.
What Could the Proposal Cost?
Greater oversight can also create additional regulatory costs. The FDA estimates that the proposal could result in approximately $89.6 million in present-value costs over 10 years, including the additional work companies would need to complete GRAS notifications.
This creates a policy tradeoff between greater oversight and transparency and the administrative burden placed on companies. Smaller businesses, in particular, could face additional costs from new reporting requirements.
What Does This Mean for Consumers?
The proposal does not mean that foods currently containing GRAS substances have suddenly been declared unsafe. It also does not mean that every GRAS substance is dangerous.
Instead, the proposal concerns how companies report GRAS safety determinations to the FDA and how much information the agency receives.
Food safety also depends on factors such as the substance involved, the amount used, its intended use, and the available scientific evidence. A regulatory change alone does not establish that an ingredient is harmful.
Where Does Health Equity Fit In?
Food regulation can also have a health equity dimension. Differences in income, neighborhood food environments, and access to fresh foods can influence reliance on packaged and processed foods and the exposures people experience.
There is not enough evidence to conclude that the proposed GRAS rule would reduce health disparities. However, greater transparency could potentially help regulators, researchers, and communities better understand what substances are entering the food supply and what evidence supports their safety.
The FDA's proposal ultimately raises a broader public health question: How much information should the public have about the decisions that determine what enters the food supply?
Because the rule is still being considered, the final answer will depend on how the FDA weighs transparency, public health oversight, economic costs, and regulatory burden.
References
Food and Drug Administration. (2026). Generally recognized as safe (GRAS). U.S. Department of Health and Human Services.
Food and Drug Administration. (2026). Substances generally recognized as safe (proposed rule). U.S. Department of Health and Human Services.
Maffini, M. V., Alger, H. M., Olson, E. D., & Neltner, T. G. (2021). Looking back to look forward: A review of FDA's food additives safety assessment and recommendations for modernizing its program. Comprehensive Reviews in Food Science and Food Safety, 20(2), 1264–1282.
Neltner, T., Alger, H., O'Connor, L., & Maffini, M. (2023). Out of balance: Conflicts of interest persist in food chemicals determined to be generally recognized as safe. Environmental Health, 22, 68.
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