(More) Food For Thought: Louisiana Enacts Food Product Warning Labels For 44 Chemicals

Highlights

• Louisiana's Senate Bill 14 introduces a first-of-its-kind QR code labeling mandate for food products containing any of 44 specified ingredients, effective Jan. 1, 2028. The legislation follows Texas Senate Bill 25, which requires a direct warning label for most of the same ingredients – but with different language, timing and exemptions – creating a complex, multistate regulatory patchwork.
• Ingredient bans in school meals, restaurant signage mandates, food labeling and continuing education requirements for medical professionals reflect a broader, yet coordinated push toward aggressive state-level food safety regulation. These laws are part of a fast-moving national trend, with West Virginia, Oklahoma and federal agencies also taking action on food chemicals and additives.
• Companies face real and immediate compliance risks: inconsistent labeling mandates, enforcement exposure and reputational scrutiny. Interested parties are advised to prepare for these laws, align with federal developments and build defensible, scalable compliance strategies that work across jurisdictions.

Louisiana Gov. Jeff Landry on June 27, 2025, signed Senate Bill (SB) 14, a law that, among other provisions, prohibits public and nonpublic schools that receive state funds from serving food containing any of 15 listed prohibited ingredients as of the 2028-2029 school year. Additionally, the law requires that food sold in the state that includes any of 44 listed ingredients to be labeled with a QR code indicating that additional ingredient information is available by scanning the code, which itself must link to the manufacturer's website. That website, in turn, must have a prominent disclaimer stating, "NOTICE: This product contains [insert ingredient here]. For more information about this ingredient, including FDA approvals, click HERE" (which links to the U.S. Food and Drug Administration (FDA) food chemical safety website). The labeling provisions go into effect on Jan. 1, 2028.

The Louisiana law, which was inspired by the "Make America Healthy Again" (MAHA) movement, also requires medical professionals to complete a minimum of one hour of continuing education on nutrition and public health every four years, along with the installation of warning signs at restaurants indicating that "Some menu items may contain or be prepared using seed oils." It was enacted at a signing ceremony attended by U.S. Department of Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. just five days after the enactment of Texas SB 25, a law that, among other provisions, requires the following consumer warning labeling on foods containing any of 44 ingredients: "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." (See Holland & Knight's previous alert, "Food for Thought: Texas Enacts Food Product Warning Labels for 44 Chemical Ingredients," July 2, 2025.)

These two state laws join other legislative and nonlegislative action related to chemical food additives. In March 2025, West Virginia enacted House Bill 2354, which banned seven food dyes in school food beginning Aug. 1, 2025, and banned the same seven food dyes and two additional preservatives in other foods sold in the state beginning in 2028. In June 2025, Oklahoma Gov. J. Kevin Stitt signed an executive order that (among other provisions) called for a comprehensive review of policies related to the use of artificial food dyes and recommendations to reduce their use in the state. These state efforts and federal announcements are related to a phaseout of artificial food dyes. (See Holland & Knight's previous alert, "HHS Announces Actions to Phase Out Use of Food Additives," April 25, 2025.) In addition, some companies are starting to respond to these announcements as well as to a potential new FDA post-market review framework for food chemicals with voluntary commitments to reformulate their products. (See Holland & Knight's previous alert, "FDA Initiates New Post-Market Review Framework for Food Chemicals," May 22, 2025.)

Compliance Considerations and Strategic Next Steps

In keeping with this accelerating national momentum around post-market review of food chemicals, SB 14 marks another significant development in state-level food labeling requirements. Drawing from similar compliance insights issued by Holland & Knight regarding oversight of ingredients, companies should prepare now for a multijurisdictional compliance environment.

With respect to the Louisiana law, companies that manufacture, private label distribute, distribute or sell food products in Louisiana containing any of the covered ingredients should begin compliance planning well ahead of the law's effective date of Jan. 1, 2028, for the labeling provisions.

Recommended steps include:

• Product Labeling Risk Review. Conduct a portfolio-wide audit to identify stock keeping units (SKUs) containing any of the 44 listed ingredients. This includes cross-referencing against existing FDA disclosures and intended retail distribution in Louisiana.
• Distribution in Louisiana. Work closely with brick-and-mortar retail partners in Louisiana to understand the regulatory requirements and rollout expectations. For online direct-to-consumer sales, gain an understanding of volume of sales and/or distribution into Louisiana.
• Label and Supply Chain Coordination. Collaborate with marketing and packaging teams to ensure that warning labels can be deployed in a manner consistent with the new law and in recognition of the fact that Texas and Louisiana have enacted laws that include different labeling requirements for the same ingredients. Establish protocols for verifying supplier disclosures and monitoring for reformulation updates.
• Engagement with Legislative and Regulatory Bodies. Monitor federal legislation and FDA regulatory activity, particularly for any future actions that could trigger SB 14's preemption provisions (the implementation of equivalently or more stringent federal laws or regulations).
• Litigation and Enforcement Preparedness. Evaluate internal recordkeeping and training protocols to reduce exposure to private enforcement actions or state-led investigations.
• Harmonization Across Jurisdictions. Recognize that ingredient restrictions and disclosure requirements may continue to vary at the state level – as they now do in Texas and Louisiana. Align compliance efforts with broader product stewardship frameworks and federal chemical safety initiatives.