In June 2025, Texas passed a new food labeling law that’s set to change how some packaged foods are sold. This law is known as Texas Senate Bill 25, or SB 25. If you sell food in Texas, this law may require you to rethink product labels. If you’re a consumer living in the Lone Star State, you may soon see new warning statements on your favorite products.
This article explains exactly what SB 25 is, why it was passed, and what the new requirements are. In addition to the mechanics of the law, it also explores its wider impact, consequence of non-compliance, and controversy.
What is the Texas Food Warning Bill?
SB 25, also called the Texas Food Warning Bill, is a new state law. It doesn’t ban any ingredients or stop products from being sold. It just stipulates that packaged food needs to carry a warning label if it contains certain ingredients. Alternatively, the manufacturer may adjust the product recipe to remove the ingredients.
Although food is regulated at the federal level in the U.S., SB 25 was passed by Texas and therefore only applies state-wide. However, a separate FDA regulation about front-of-package (FOP) nutrition labels is currently being finalized. This overlap is why SB 25 is often talked about alongside updated FDA food labeling in Texas, even though SB 25 itself is not an FDA rule. Here’s a summary of the two individual laws (one proposed, one passed) to help you avoid confusion.
- January 2025: The FDA proposed a federal-level regulation to include a standard nutrition label on the front of food packaging, showing saturated fat, sodium, and added sugars.
- June 2025: Unrelated, Texas passed a state law requiring warning labels on foods containing certain products.
What the New Food Labels Need to Say
If a food product contains one of the ingredients listed in Section 431.0185, Chapter 431 of the Texas Health and Safety Code, its label must include a warning. The warning must say that the product contains an ingredient that is not recommended for human consumption by the relevant authorities in Australia, Canada, the European Union, or the United Kingdom.
The idea behind this warning is to give you more information about the food you buy. It’s not designed to scare you. It doesn’t say that the product is unsafe or the ingredient is illegal in the U.S. It simply points out that regulators elsewhere take a different view. It’s left to you, the consumer, to make a more informed decision.
There are also certain rules around how the warning must appear on packaging. It has to be easy to see, read, and understand under normal conditions. The font should contrast against the background. It should also be at least the same size as other consumer information on the packaging (like the allergens list).
The 44 Ingredients SB 25 Covers
Currently, the list contains 44 food additives, colors, and chemicals. It includes things like bleached flour, interesterified palm oil, Red 3, titanium dioxide, and Yellow 6. Texas didn’t come up with this list based on FDA safety findings.
Instead, it’s based on how other countries regulate certain additives and ingredients. An ingredient ends up on the list if regulators have restricted, discouraged, or banned it in food for human consumption in:
- Australia
- Canada
- The 27 countries in the EU
- The United Kingdom
It’s important to note that most of these ingredients are still allowed under U.S. federal law. Others, like Red 3, have been banned (pending implementation in January 2027). Many of the ingredients are found in popular processed foods, like Flamin Hot Cheetos (Red 40, Yellow 5 & 6) and Lucky Charms (Blue 1, Red 40, Yellow 5 & 6).
Pretzels, bagels, bread, and other baked items like Pop-Tarts often contain several ingredients on the list, like potassium bromate, bleached flour, stearyl tartrate, and partially hydrogenated oil (PHO). It doesn’t matter what the concentration is. If one or more ingredients is present and the food is being sold in Texas, the warning is required.
FDA Regulation and Texas Law
SB 25 doesn’t replace FDA rules. It sits on top of them, so a product can fully meet FDA requirements but still need an additional warning label in Texas. If you’re a food manufacturer, that means you can’t rely on FDA approval alone. You must still comply with SB 25.
If you only sell food in the state of Texas, you’ll either need to rethink your recipe or overhaul the packaging, which could have knock-on effects on your brand image. If you sell food across the U.S., it adds an extra layer of complications. You may end up with one version of your packaging for Texas and another version for the rest of the country.
The New Food Labeling Law Effective Date
The new law doesn’t kick in immediately, so you have time to prepare. Although SB 25 became effective in September 2025 having been signed by Governor Abbott three months prior, compliance isn’t expected until January 2027.
The reason for the delayed mandates is to allow manufacturers to consider their options. Some may prefer to remove the ingredients in order to avoid the labeling requirements. Others may decide to redesign packaging to include the warning. Either way, these things take resources, manpower, planning, and time.
The law applies to products solid in Texas after enforcement begins. It doesn’t look back and punish products sold beforehand. Even so, packaging, inventory, and distribution changes aren’t something you can fix last minute.
Consequences for Non-Compliance
If you sell a food product in Texas and fail to update the packaging with the necessary warning, you open yourself up to enforcement action by the Attorney General. This carries some hefty civil penalties of up to $50,000 per day for each product not in compliance.
You may also be ordered to reimburse the state for the costs of the investigation and bringing the enforcement action. As you can imagine, those costs will add up quickly. Having just three products which violate the rules for one month could land you with up to $4.5 million in penalties alone.
Controversy
SB 25 has initiated strong reactions from food companies, trade groups, and legal experts. Critics argue it could confuse consumers and undermine national food safety standards. Because of these concerns, there is a certain level of uncertainty around the law. As of right now, it’s still moving forward, but it’s wise to keep a close eye on any developments. If you sell food in Texas, the safest approach is to assume the law will apply and plan accordingly.
Endnote
Ultimately, the key takeaways are that SB 25 doesn’t ban ingredients or rewrite FDA rules. It changes what you’re told at the point of sale. If a product contains one of the 44 ingredients listed in Texas Health & Safety Code § 431.0815, it must carry a warning label. As a producer, it affects how you package and distribute your products. As a consumer, it affects how you read and interpret food labels. Overall, it’s designed to bring greater awareness across the board, contributing to a more informed and healthier Texan population.
