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 took over a month to catch up with one of them, and, as of its most recent update, still lists the other 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 seventeen 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 September 15, 2026 (the tracker's most recent update), 31 companies and trade associations appear on it (PepsiCo is listed twice, once per product line, so 30 distinct companies). Eleven 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), Tyson Foods, Mars, Aramark Student Nutrition, Otis Spunkmeyer, and, added in the tracker's September update, Campbell's.
The other twenty (including General Mills, The Kraft Heinz Company, The Hershey Company, Conagra Brands, Walmart, Danone U.S., PepsiCo's Gatorade line, Mondelez International, Kellanova, and WK Kellogg Co) are still listed "In progress."
Company claims versus the FDA tracker
That's where the trade-press gap opened. FoodNavigator reported in mid-August that both Campbell's and Kellogg had self-announced reformulation completion earlier in the month. For about five weeks, neither company's status on FDA's tracker moved.
Campbell's has since caught up (the tracker listed it "Complete" as of its September update), but WK Kellogg Co's hasn't: the company announced completion in early August, and the government's own record still shows "in progress" more than a month later. 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. Campbell's case supports the lag explanation; Kellogg's still-open gap suggests the two aren't saying the same thing yet.
How we got here
The pledge program is 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 differ
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 shows
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.
What PurityIQ shows
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 (content current as of Sep. 15, 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 October 9, 2026 (corrected; underlying tracker data current as of Sep. 15, 2026).