On January 11, 2018, the U.S. Food and Drug Administration released its Strategic Policy Roadmap for 2018.

As part of its Strategic Policy Roadmap, FDA has signaled its intent to modernize certain standards of identity to address current barriers to the development of healthier products while making sure consumers have accurate information about the foods they eat. To accomplish this goal, FDA intends to issue a request for information to identify and help prioritize which potential standards of identity should be modernized based on their public health value.

The modernization of certain standards of identity could conceivably lead the FDA to wade into the controversial plant-based milk and cheese debate this year.  It remains to be seen which standards the Agency ultimately decides to tackle. Finally, we estimate that the process will take many years to complete as it involves formal notice and comment rulemaking possibly including revisions to existing regulations and promulgation of new regulations.