The Reformulation Wave Is Here

For years, reformulation was something food and beverage companies generally did when they had to. An ingredient became unavailable. Customer’s demanded a cleaner label. Costs got out of control. A retailer changed its standards. Or a regulatory change forced the issue.

While this still happens, the food and beverage industry is entering one of the largest reformulation cycles we have seen in decades. Regulatory pressure is increasing, consumers are scrutinizing ingredient labels more closely, artificial additives are under pressure, sugar remains a major target, protein and fortification continue to gain importance, and new technologies are making it possible to formulate products differently than we could have even five or ten years ago.

The MAHA movement has certainly accelerated the conversation, but this is bigger than one administration or political movement.

In January 2025, the FDA revoked authorization for Red No. 3 in foods, requiring manufacturers to remove it by January 2027. HHS and FDA have also announced an initiative aimed at phasing petroleum-based synthetic dyes out of the U.S. food supply, including Red 40, Yellow 5, Yellow 6, Blue 1, Blue 2 and Green 3. At the same time, FDA is reconsidering how ingredients enter the food supply through the GRAS process and has identified a proposed GRAS rule as a 2026 priority.

The United States is not suddenly adopting the European regulatory system, but the direction is hard to ignore. The European Union operates under a more restrictive positive-list approach to food additives and has already removed ingredients such as titanium dioxide as an authorized food additive. American regulators, retailers and consumers are increasingly asking similar questions about what belongs in food and why it is there.

But getting consumed by the potential regulatory chaos misses the bigger point.

Brands that treat reformulation purely as a compliance exercise may miss one of the best product-improvement opportunities they have had in years.

Consumers Have Changed

Consumers have become much more sophisticated about food. They read labels. They recognize ingredients. They compare grams of sugar and protein. Parents look at what they are feeding their kids. Social media can turn an obscure ingredient into a national discussion almost overnight.

That does not mean consumers suddenly understand food science. Plenty of perfectly safe or functional ingredients have names that consumers don't recognize. But perception matters, and the gap between what formulators understand and what consumers are comfortable seeing on an ingredient statement has become a commercial issue.

At the same time, expectations have increased. Consumers increasingly want lower sugar, more protein, fewer calories, recognizable ingredients, functional benefits and great taste—often simultaneously.

That is not an easy formulation brief. But it creates an opportunity for brands that can deliver it.

Sugar Is Becoming One of the Biggest Reformulation Targets

Sugar reduction is no longer limited to diet products. For many categories, it has become a central part of product development.

The challenge is that sugar does far more than provide sweetness. Depending on the application, it contributes body, mouthfeel, browning, texture, solids and preservation. Removing 30% of the sugar does not necessarily mean adding enough sweetener to replace 30% of the sweetness.

The entire system may need to be rebuilt.

Fortunately, sweetener technology has improved dramatically. Gone are the days when replacing sugar automatically meant an overpowering metallic or bitter stevia note. Better stevia fractions, monk fruit, allulose and other sweetening systems—combined with flavor modulation and masking technologies—can produce much more convincing sweetness profiles.

In the right application, these systems can replace a meaningful portion of the sugar without destroying the product.

Sometimes there is another benefit: economics. Products using significant quantities of cane sugar or other caloric sweeteners may be able to reduce ingredient cost depending on the replacement system, usage rate and application. Reformulation can therefore become both a nutritional improvement and a margin project.

That is a very different conversation from simply saying, “We need to reduce sugar.”

Protein and Fortification Are Reshaping Categories

Protein is another major force changing formulation strategy. The GLP-1 era is only accelerating it.

For years, snack companies responded to calorie-conscious consumers largely through portion control and smaller formats. That strategy still exists, but the conversation is shifting toward nutrient density.

If consumers are eating less, many want what they eat to work harder for their bodies.

That means more interest in protein, fiber, vitamins, minerals, electrolytes and other forms of fortification. A snack that historically competed primarily on indulgence may increasingly need to answer another question: What am I getting from these calories?

That creates opportunities far beyond protein shakes and bars. Beverages, baked goods, snacks, dairy products, confectionery and even traditionally indulgent categories are experimenting with higher-protein or functionally fortified formulations. Or better called “reduced guilt” products.

But simply dumping protein into a formula is not innovation.

Proteins affect flavor, viscosity, texture, stability, processing and shelf life. Different sources behave very differently. Consumers also increasingly distinguish between types of protein—whey versus plant, isolate versus concentrate, conventional dairy versus grass-fed or A2.

Formulators have to understand not only how much protein they can add, but which protein makes sense for the consumer, application and economics. Sometimes protein stability, say in a beverage, can take months to formulate and stabilize.

Natural Colors Are Finally Catching Up

Color is another obvious reformulation battleground. Artificial colors have historically offered formulators several significant advantages: they are inexpensive, vibrant, consistent and highly stable. Natural colors have not always been able to match them. But, that gap is narrowing.

There has been significant progress in natural color technology, including improvements in vibrancy, heat stability, light stability and performance across different pH environments. FDA has also expanded the available palette by authorizing additional color additives from natural sources.

There is still generally a cost differential, and converting an artificial color system to natural is rarely a simple one-for-one substitution. Have you seen Canadian Fruit Loops vs American Fruit Loops?

A natural red may respond differently to heat. A blue may behave differently at a particular pH. A beverage that looks perfect on day one may fade several months later. Packaging itself may suddenly become part of the formulation discussion because of light exposure.

That means validation, accelerated shelf-life testing and sensory work matter.

Companies waiting until the last minute to make these conversions may discover that the replacement they assumed would take a few weeks actually requires months.

The Ingredient Panel Itself Has Become Part of the Product

For many brands, reformulation is increasingly about subtraction. Shorter ingredient statements. Fewer unfamiliar names. Ingredients consumers recognize.

This does not mean the shortest ingredient deck automatically makes the best product. That is an oversimplification. Food still needs to taste good, remain safe, survive distribution and deliver an acceptable shelf life. But ingredient simplicity has become part of the consumer experience.

A brand can spend millions of dollars developing beautiful packaging and telling a clean, modern brand story, only to undermine it with an ingredient statement that feels like it belongs to a different generation of products.

The front of the package and the back of the package increasingly need to tell the same story.

Why Getting Ahead Matters

There is another reason we encourage companies to start thinking about reformulation before they are forced to. Everybody else may eventually be trying to reformulate at the same time.

That creates several problems:

1. Ingredient supply can disappear quickly.

The recent pressure in protein markets is a good example. Specialized proteins—including certain premium dairy proteins—can become constrained, and rapidly growing demand can push pricing higher. If thousands of products simultaneously move toward the same natural colors, sweeteners, proteins or functional ingredients, suppliers will allocate capacity somewhere.

Established customers with predictable volumes and existing supplier relationships are in a far stronger position than the company showing up after the rush has started. This is also why backup supply should be part of almost every significant reformulation project.

I have seen SKUs effectively die because a key raw material became unavailable and there was no qualified alternative. That is avoidable.

2. Better products can create stronger consumer trust.

The best reformulations should not feel like compromises. They should make consumers more comfortable buying the product.

If you can meaningfully reduce sugar, simplify the ingredient panel, remove ingredients consumers increasingly avoid, or add meaningful nutrition without sacrificing taste, texture or enjoyment, you may strengthen the relationship with existing customers.

You may also reach consumers who previously rejected the product because of its nutritional profile or ingredient statement.

There is a major difference between reformulating so that a product remains legal and reformulating so that a consumer feels better about buying it.

3. Reformulation takes longer than most executives expect.

I have seen formulation changes happen in an afternoon. I have also seen them take months. The timeline depends on the product, processing conditions, packaging, shelf life, target cost, ingredient availability, sensory expectations and how ambitious the reformulation actually is.

Changing one ingredient can create three new problems. Reduce sugar and the mouthfeel changes. Add protein and viscosity changes. Switch colors and shelf stability changes. Change an emulsifier and the product separates. Formulation is a system of trial and error and continuous improvement.

That is why experienced R&D partners, ingredient suppliers, flavor houses, co-manufacturers and commercialization teams become important. The earlier those groups are involved, the more options a brand generally has.

4. Waiting can make the project unnecessarily expensive.

Imagine an industry simultaneously trying to remove the same artificial colors or reformulate around the same regulatory deadline. Ingredient suppliers become overloaded. Application labs become backed up. Flavor houses have limited bench capacity. Co-manufacturers need new trials. Shelf-life studies cannot be compressed simply because a deadline is approaching.

Suddenly, everyone wants the same technical resources at the same time. The company that started twelve months earlier has options. The company starting ninety days before a deadline has problems.

5. Reformulation can improve economics—not just ingredients.

This is the piece that companies frequently overlook. If you are already opening the formula, why only replace the ingredient creating the problem?

Look at the whole product and ask these questions:

Can you reduce ingredient cost?

Can you eliminate an unnecessary component?

Can you increase solids efficiency?

Can you improve yield?

Can you simplify manufacturing?

Can you consolidate ingredients across multiple SKUs?

Can you qualify an alternative supplier?

Can you improve shelf life and reduce spoilage?

Can you reduce freight by changing concentration or packaging format?

A mandatory reformulation project can become an excuse to rebuild the economics of the SKU. That is where the strategic value lies.

Don't Reformulate Backward

One of the biggest mistakes a brand can make is attempting to reproduce yesterday's product with tomorrow's ingredients.

Sometimes that is necessary. A highly loyal consumer base may demand almost perfect sensory equivalence. But other times, reformulation should be approached differently.

Instead of asking: “How do we replace this ingredient without anyone noticing?”

Ask: “If we were launching this product today, knowing what we know about consumers, ingredients, technology and our economics, would we formulate it the same way?”

That question can lead to a much better outcome.

The Take Away

The regulatory environment around food ingredients will continue to evolve. So will consumer expectations. Trying to predict every ingredient that regulators may scrutinize next is probably impossible. Building an organization that can respond quickly is not.

Brands should know where their ingredient risks sit, which materials have limited supplier options, which formulas are most exposed to changing consumer expectations, and which SKUs offer the biggest opportunity for nutritional, sensory or economic improvement.

The reformulation wave is coming whether companies want it or not.

The winners will not be the companies that simply comply first. They will be the companies that strategized ahead of competitors and use the reformulation opportunity to make their products better.

If your company is evaluating a reformulation project, Nubev Strategic can help develop the strategy, identify the right technical partners and determine where reformulation can create value beyond simply replacing an ingredient.