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Colors/Dyes

FDA's voluntary dye-pledge tracker: which brands actually reformulated

Published September 28, 2026

Facts verified as of August 29, 2026

Two of the country's largest food companies told trade press in early August they'd finished pulling petroleum-based dyes from their products. The FDA's own tracker, updated after those announcements, still lists both as "in progress."

That gap — between what a company says publicly and what the government's own record shows — is the actual story behind the dye phase-out fourteen months in.

What just happened

In April 2025, HHS and the FDA announced a coordinated push to phase petroleum-based synthetic dyes out of the U.S. food supply, building on the formal revocation of FD&C Red No. 3's authorization that January (90 Fed. Reg. 4628, Jan. 16, 2025). Unlike the Red No. 3 action, which was a binding legal revocation with a compliance deadline, the broader dye phase-out is a voluntary pledge program: companies agree to reformulate on their own timeline, and the FDA tracks their self-reported progress on a public page.

As of August 11, 2026 — the tracker's most recent update — 26 companies and trade associations appear on it. Seven are marked "Complete": Target, Sam's Club, In-N-Out Burger, Nestlé USA, PepsiCo's Frito-Lay dye lineup (Cheetos, Doritos), PIM Brands (Welch's), and Tyson Foods. The other nineteen — including General Mills, The Kraft Heinz Company, Mars, The Hershey Company, Conagra Brands, Walmart, Danone U.S., PepsiCo's Gatorade line, and both Campbell's and WK Kellogg Co — are still listed "In progress."

That's where the trade-press gap opens. FoodNavigator reported in mid-August that both Campbell's and Kellogg had self-announced reformulation completion earlier in the month. Neither company's status on FDA's tracker has moved. That could mean the tracker lags a company's internal timeline, or it could mean "complete" means something looser in a press release than it does on a federal tracking page updated by the agency itself. Nothing in the public record resolves which explanation is correct — which is itself worth knowing before taking either source's word for it.

How we got here

The pledge program didn't emerge from a single new finding. It's built on top of two other 2025-2026 actions: the Red No. 3 revocation in January 2025, which affected one dye under a hard legal deadline, and a separate FDA letter to industry in February 2026 clarifying what "no artificial colors" can and can't legally mean on a label, tied to the existing labeling regulation at 21 CFR 101.22(a)(4). Together, the three actions describe three different levels of government pressure: one formal revocation, one voluntary industry pledge, and one labeling-language clarification. Treating any of the three as interchangeable — "FDA banned food dyes" — overstates all of them.

Where regulators diverge

The EU has never operated on a pledge-and-track model for this category. Where a synthetic dye remains authorized in the EU, it typically carries a mandatory warning label under EU Regulation 1333/2008 rather than a voluntary removal pathway — the "may have an adverse effect on activity and attention in children" label required on certain dyes since 2010. The U.S. approach, by contrast, is now running two tracks at once for the same category of dyes: a formal, non-negotiable revocation for one (Red No. 3) and a self-reported, voluntary pledge for the rest. That's also a reverse case worth naming plainly: on Red No. 3 specifically, the U.S. moved to a binding revocation while the EU's warning-label approach leaves the dye on shelves with a label. Neither posture is strictly stricter across the board; they're structured differently, and a company's tracker status in the U.S. isn't equivalent to a compliance date in the EU.

What the label actually says

If a company is listed "Complete," its reformulated products should carry the replacement colorant on the ingredient list — commonly a fruit, vegetable, or mineral-based colorant rather than an FD&C-numbered dye. If a company is "In progress," existing FD&C-dyed products can still legally be on shelves; there's no federal deadline forcing a pull date the way there was for Red No. 3. And under the FDA's February 2026 letter, a product can't claim "no artificial colors" on its label while still using a dye the agency defines as artificial under 21 CFR 101.22(a)(4) — a narrower rule than shoppers might assume from the phrase alone.

PurityIQ tie-in

This is exactly the kind of gap PurityIQ exists to surface: not a verdict on any company, just the public record — the FDA's own tracker, dated and sourced — set next to what a company said about itself. You see both. You decide what "complete" is worth to you.

Sources

FDA, Tracking Food Industry Pledges to Remove Petroleum-Based Food Dyes (updated Aug. 11, 2026) — https://www.fda.gov/food/color-additives-information-consumers/tracking-food-industry-pledges-remove-petroleum-based-food-dyes

HHS/FDA press release, "Phase Out Petroleum-Based Synthetic Dyes" (Apr. 22, 2025) — https://www.fda.gov/news-events/press-announcements/hhs-fda-phase-out-petroleum-based-synthetic-dyes-nations-food-supply

FDA, Letter to Food Industry on "No Artificial Colors" Labeling Claims (Feb. 5, 2026) — https://www.fda.gov/food/food-chemical-safety/letter-food-industry-no-artificial-colors-labeling-claims

21 CFR 101.22(a)(4) — https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.22

90 Fed. Reg. 4628 (Jan. 16, 2025) — Red No. 3 revocation

EU Regulation (EC) No 1333/2008, Annex V (mandatory warning label)

As of September 1, 2026.

PUSHED 2026-09-01: Live on Lovable blog at https://purityiq.app/blog/the-fda-is-tracking-who-kept-their-promise-to-remove-food-dyes-its-own-tracker (scheduled published_at 2026-09-28, blog_posts id a4fe5339-8cad-4e84-be56-16a7f2bc70a5). Beehiiv draft created: https://app.beehiiv.com/posts/9fb10e76-3bea-45bb-b868-f04fbcadd81a/edit — needs a human Schedule/Send click in the Beehiiv UI, MCP cannot do that step.

Sources

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