GRAS Under Pressure: What FDA’s Proposed Rule Means for Functional Foods and Beverages

FDA’s proposed mandatory GRAS notification rule could significantly change how functional food and beverage companies evaluate ingredients, work with suppliers, and bring products to market. Join Venable attorneys Todd Harrison and Claudia Lewis who will break down the proposal and its practical implications, including which ingredients and uses may be covered, who may be responsible for filing, how companies can rely on supplier GRAS determinations, and what the rule could mean for existing products and dual-use food and supplement ingredients. They will also discuss steps companies should consider taking now, including evaluating their GRAS portfolios and supply chains and weighing whether to submit comments before the December 9, 2026, deadline.