Any time I write about the government, or about government officials, I’m bound to ruffle a few feathers.

So, chances are, if you read this, you’re going to be one of those people who think I need to stay in my lane.

That’s not really what I do…not that I’m passionate about stirring up controversy…more that I’m passionate about human health.

I believe that the government sometimes interferes with human health. Not because it’s inherently evil…more that it is comprised of individuals who are far from perfect, and collectively they make decisions or rules that are cumbersome, bureaucratic, or short-sighted.

That’s the GRAS system in a nutshell.

Today, I’ll talk about how RFK and his team are looking to reform it so it actually does what it’s meant to do.

GRAS: The Food-Safety Gap RFK Jr. Is Trying to Close

Most people assume that when a new ingredient appears in the food supply, the FDA has reviewed it first.

But that’s not true.

The reason comes down to a regulatory category called GRAS, short for “Generally Recognized as Safe.”

GRAS was created for substances that qualified experts consider safe under specific conditions. Some substances qualify because they have a long history of use.

Others qualify based on scientific evidence.

There’s an important distinction here: GRAS isn’t supposed to mean “we have no idea whether this is safe,” but that’s kind of where it has fallen today.

FDA regulations say a GRAS conclusion based on scientific procedures should rely on the same quantity and quality of evidence needed for food-additive approval.

The weakness has been who has to see that evidence.

Under the current system, a company can independently conclude that an ingredient is GRAS and isn’t necessarily required to notify the FDA. That means the agency may not know every substance entering the food supply under this pathway, much less have independently evaluated it.

That gap has bothered food-safety researchers for years.

Robert F. Kennedy Jr. and current HHS and FDA leadership have now paid much more attention to fixing it.

Here’s What Kennedy Is Actually Trying to Change

In March 2025, HHS Secretary Kennedy directed the FDA to explore eliminating what is commonly called the self-affirmed GRAS pathway.

His argument was straightforward:

If manufacturers can introduce ingredients while keeping their GRAS conclusions outside FDA’s notification system, regulators and the public may not have a complete picture of what’s being used in food.

That effort has now moved beyond discussion.

Which I’m sure many of you would argue is a positive thing.

On August 10, 2026, the FDA proposed a new rule requiring GRAS notices for covered new uses of substances in human and animal food.

The agency would also maintain a more complete public inventory. Again, a move in the right direction compared to where we’re at today.

The rule is still proposed, not final. Public comments remain open through December 9, 2026.

That’s an important update from earlier reporting on this issue.

Kennedy didn’t simply announce that the loophole would disappear. The FDA has begun the regulatory process that could make notification mandatory.

From my perspective, the biggest issue isn’t that every GRAS ingredient should be viewed as dangerous.

I’m not crazy, and that would be an enormous leap beyond the evidence.

The problem is a safety system works better when the people responsible for oversight know what they’re overseeing.

Independent research has also raised concerns about compromises in the review system.

A 2013 study examined 451 GRAS notices voluntarily submitted between 1997 and 2012. In every case, the manufacturer or its consultant selected the people making the safety determination. About 22% of assessments were performed by an employee of the manufacturer itself.

The researchers concluded that financial conflicts of interest were widespread enough to raise legitimate questions about the process’s integrity.

This is something you see in medicine all the time, and it’s a good enough reason to shake things up with the GRAS.

A 2023 follow-up examined 403 GRAS notices filed between 2015 and 2020. Researchers found that a relatively small group of experts repeatedly served on industry-selected panels, and they reported little evidence that panels had adopted important elements of FDA guidance intended to limit conflicts and bias.

Again, conflict of interest doesn’t prove an ingredient is unsafe, but it can absolutely tell us the process could benefit from more independent scrutiny.

Another Thing People Get Wrong around GRAS

Another thing about GRAS that has to be contended for is how science changes.

That may be one of the strongest arguments for better post-market review.

The role of partially hydrogenated oils in the decline of human health is a great example.

These oils were once treated as GRAS and became a major source of artificial trans fat in processed food. As evidence accumulated linking trans fat with harmful changes in cholesterol and cardiovascular risk, the FDA revisited the issue.

In 2015, the agency determined that partially hydrogenated oils were no longer GRAS, eventually removing most uses from the food supply.

It’s great that the GRAS reflected emerging evidence, but it also shows why the GRAS assessment needs scrutiny. 

I think this illustrates something larger too.

“Safe” shouldn’t be treated as a tattoo stamped onto an ingredient forever. Exposure changes. Manufacturing changes. Consumption patterns change. New studies appear.

A good safety system needs to change too, don’t you think?

The FDA has recently expanded that work. In 2026, it launched or continued formal reassessments of several food chemicals, including BHA, BHT, and certain phthalates.

The Proposed Fix Still Has Limits

The new GRAS proposal would create much more visibility for new uses that otherwise could have entered commerce through an independent GRAS conclusion.

But it doesn’t mean the FDA is about to perform a complete new toxicology review on every ingredient already in American food.

For certain substances already in commerce before a final rule takes effect, the proposal creates a streamlined reporting option.

Manufacturers could provide identifying information, conditions of use, and evidence that the ingredient was already being marketed.

Importantly, the FDA says placing that information on a public list would not mean the agency had reviewed and confirmed the substance’s GRAS status.

That tells me the reform is meaningful, but it isn’t magic.

It helps close an information gap. Continued post-market safety reviews will still matter.

What You Should Do Right Now

Just because the GRAS system doesn’t do it perfectly now doesn’t mean you need to panic.

Especially if you’re sticking to “real food” most of the time.

If you do that, you won’t need to memorize hundreds of additives or stand in the grocery store searching every ingredient on your phone.

In my opinion, a simple strategy that reduces unnecessary exposure by shifting more of the diet toward recognizable, minimally processed foods (vegetables, fruit, beans, lentils, eggs, fish, meat, nuts, seeds, plain dairy, oats, rice, and other basic foods) will make it so something like GRAS doesn’t matter to you.

But when you decide to stray from those foods (which is your right), knowing what you eat will help.

But I wouldn’t make ingredient count an obsession either.

At the end of the day, I don’t see GRAS reform as a reason to declare the American food supply toxic.

I see it as an overdue attempt to make a safety system more complete.

Kennedy and his HHS/FDA team have brought new political momentum to the issue, but many of the concerns they’re addressing—including voluntary notification, incomplete FDA visibility, conflicts of interest, and inadequate reassessment—were documented well before this administration.

The useful question isn’t whether every GRAS ingredient is bad.

It’s whether a modern food system should rely on safety determinations that regulators may never even know were made.

I think more transparency, mandatory notification for new GRAS uses, independent scrutiny, and systematic reassessment make sense.

For patients, the approach can remain much simpler.

Build most meals from foods with a nutritional purpose. Use packaged foods where they make life easier. Read labels when there’s a reasonable alternative. Don’t panic over every unfamiliar ingredient.

And let better regulation do the job that individual shoppers were never really equipped to do on their own.