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U.S. Bill Would Create Board to Review Self-determined, Pre-2000 GRAS Substances
Wednesday, February 11, 2026

On February 3, 2026, Rep. Mike Lawler (R-NY) introduced the GRAS Oversight and Transparency Act, legislation that would require a newly-created Board to review all “Covered GRAS designations,” which are defined as substances that were designated by their manufacturers as Generally Recognized as Safe (GRAS) prior to 2000. Voting members of the Board would include the Secretary of Health and Human Services, the Secretary of Agriculture, and other staff members from those agencies, in addition to a specialist in toxicology from the Environmental Protective Agency. The Board would also include a representative from the food manufacturing industry and an academic expert in food toxicology.

The legislation would require food manufacturers to identify each covered GRAS designation attributed to them within 90 days. The Board would then assign each substance to one of three categories based on its priority for review. The substances would then be reviewed to “determine the validity of each such designation.” The Board would be required to notify the Secretary and Congress of any determination that a substance has not been shown to be safe within 90 days of completing the review.

Another GRAS-related bill, the Better Food Disclosure Act of 2025 (S. 3122), was introduced by Senator Robert Marshall (R-KS) on November 6, 2025. It would require that GRAS substances already in use must be reported and listed publicly by the U.S. Food and Drug Administration (FDA) within two years of enactment. It would also require that all new GRAS substances be notified to FDA 120 days before their first use in food introduced into interstate commerce. S.3122 was referred to the Senate Committee on Health, Education, Labor, and Pensions. For more information on that bill, see the packaginglaw.com article, Congress Moves to Strengthen FDA Oversight of Food Substances with “Better Food Disclosure Act of 2025.

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