Louisiana and Texas recently enacted new legislation imposing disclosure requirements on food and beverage manufacturers, as well as new restrictions on ingredients permitted in public school meals. Some changes take effect as soon as September 1, 2025, with others rolling out in the next few years. This Update outlines these new state laws.
Louisiana's SB 14: Food Ingredient Disclosure and School Nutrition Restrictions
Louisiana Governor Jeff Landry signed SB 14 into law on June 20, 2025, introducing new requirements for food ingredient disclosures and restrictions on certain ingredients in school meals. Louisiana SB 14 introduces the following key requirements:
- Effective January 1, 2028, food products offered for sale in the state containing any of 44 specified ingredients—including potassium bromate, various food dyes, aspartame, and sucralose—must display a QR code on the packaging. A statement adjacent to the code must inform consumers that additional ingredient information is available by scanning the code. The linked webpage must include the following disclaimer: "NOTICE: This product contains [insert ingredient here]. For more information about this ingredient, including FDA approvals, click HERE." The disclaimer must also provide a link to the U.S. Food and Drug Administration's (FDA) food chemical safety webpage.
- Beginning with the 2028-2029 school year, Louisiana public schools and nonpublic schools receiving state funds will be prohibited from serving meals containing any of 15 specified ingredients, including certain food dyes, potassium bromate, acesulfame potassium, aspartame, and sucralose. This restriction does not apply to foods or beverages sold in concession stands or vending machines. Notably, acesulfame potassium, aspartame, and sucralose remain FDA-approved food additives.
- As of January 1, 2028, food service establishments using seed oil, including canola oil or corn oil, in food preparation must disclose the potential presence of seed oil to customers via a disclaimer on the menu or another clearly visible location.
- Separately, the legislation requires physicians, physician assistants, and advance practice registered nurses in various specialty areas to complete a minimum of one hour of continuing education on nutrition and metabolic health every four years.
Texas' SB 25: "Make Texas Healthy Again" Act
Texas Governor Greg Abbott signed SB 25, also known as the "Make Texas Healthy Again" bill, into law on June 22, 2025. The legislation goes into effect September 1, 2025. Key provisions include:
- The Texas Nutrition Advisory Committee will be established to develop nutritional guidelines for residents of Texas.
- Manufacturers of food products offered for sale in the state must include a warning label if a product contains any of 44 specified ingredients. The label must read: "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." This requirement applies to product labels developed or copyrighted on or after January 1, 2027.
- The bill contains a federal preemption provision which states that a warning label is not required if either FDA or the U.S. Department of Agriculture have issued a law or regulation that (1) specifically prohibits the use of the ingredient, (2) imposes conditions on the use of the ingredient, (3) determines an ingredient or class of ingredients is safe for human consumption, or (4) requires a label statement relating to ultra-processed or processed foods.
- Similar to the Louisiana legislation, SB 24 requires physicians and other health professionals to complete continuing education on nutrition and metabolic health. The precise number of hours required is delegated to the relevant credentialing board.
These are new requirements. If you have any questions about these new laws or how they may affect your operations, please contact members of Perkins Coie's food regulatory team.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
