Texas Senate Bill 25: Key Steps Food Manufacturers Must Take by 2027

Food and beverage brands operating in Texas need to prepare for one of the most sweeping labeling changes in recent history. Here’s what you need to know and how to respond with speed and flexibility.

On June 22, 2025, Texas Governor Greg Abbott signed Senate Bill 25 (SB 25) into law. This legislation introduces significant new labeling requirements for foods containing certain ingredients and establishes the Texas Nutrition Advisory Committee to develop nutritional guidelines. The bill will become effective on September 1, 2025, with specific compliance deadlines phased in over the next several years.

What does SB 25 mean for your business?

1. Does it apply to you? The law applies to food products sold in Texas, regardless of where the product was originally produced. Any manufacturer offering products for sale in the state, whether based within or outside Texas, must comply with the labeling requirements.

2. What’s changing for food labels? SB 25 requires food manufacturers and sellers to include a prominent consumer warning label on products containing any of 44 specified ingredients. These include

• Artificial colors (e.g., red 40, yellow 5, blue 1)

• Preservatives (e.g., BHA, BHT)

• Other additives (e.g., potassium bromate, titanium dioxide)

The required warning text is: “WARNING: This product contains an ingredient that is not recommended for human consumption by the appropriate authority in Australia, Canada, the European Union, or the United Kingdom.”

The warning must appear in a highly visible location, with clear contrast, and in a font size no smaller than the smallest font used for other mandatory consumer information on the package.

3. Are you exempt? The labeling requirements do not apply to:

• Food not intended for human consumption.

• Food prepared, served, or sold in restaurants or retail establishments.

• Products regulated by the USDA’s Food Safety and Inspection Service.

• Drugs, dietary supplements, or agricultural chemicals used in production.

4. Important deadlines to know

• Rule adoption deadline: By December 31, 2025, the executive commissioner of the Health and Human Services Commission must adopt rules to implement food labeling requirements. These rules will guide manufacturers in preparing for compliance.

• Implementation of warning labels on food products: Food products that are required to include ingredient warnings must comply with the new labeling requirements if the product label is developed or copyrighted on or after January 1, 2027 (Section 19(b)). Manufacturers should begin compliance planning immediately to meet the deadline.

• Federal preemption clause: If federal laws or regulations are enacted on or after September 1, 2025 (the effective date of this Act), and those federal laws address the same ingredients or labeling requirements, the state provisions under Section 431.0815 will no longer apply (Section 431.0817).

5. What happens if you don’t comply? The Texas Attorney General may seek civil penalties of up to $50,000 per day per distinct food product in violation of the law (Section 431.0816(b)(1)). Additional penalties may include reimbursement of investigation and enforcement costs.

6. Adding the warning to packaging: Manufacturers have two primary options for adding the new consumer warnings to their product packaging:

• Update existing packaging artwork: This option involves modifying the existing artwork used by packaging converters to integrate the warning into the overall design. It’s a great choice for long-term compliance but may require extra lead time for design changes, approvals, and production adjustments.

• Use in-line printing for flexibility: For a faster or more temporary solution, manufacturers can use in-line printing to add the warning directly onto the packaging during production, provided there is sufficient space on the packaging. This method allows for quick adaptation without needing to rework pre-printed materials.

Companies like Videojet offer advanced in-line printing solutions to help manufacturers meet these requirements efficiently and cost-effectively.

Action steps for food manufacturers

Manufacturers selling food products in Texas should take the following steps to ensure compliance with SB 25:

1. Review ingredients: Assess product formulations to identify any of the 44 regulated ingredients that require warning labels.

2. Plan label updates: Update packaging, websites, and promotional materials to meet the new labeling requirements by the January 1, 2027 compliance deadline.

3. Participate in rulemaking: Engage with the state’s regulatory process to help clarify compliance expectations and ensure alignment with finalized guidelines.

4. Evaluate packaging solutions: Decide whether to update packaging artwork through converters for long-term compliance or to use in-line printing for flexibility and faster updates.

5. Stay informed: Monitor regulatory updates to stay ahead of changes and ensure compliance with key deadlines, especially the January 1, 2027 label implementation requirement.

By taking these proactive steps, manufacturers can work toward compliance with SB 25, avoid potential penalties, and continue selling their products in the Texas market without disruption.