The system begins with a split review path
FDA says food additives and color additives generally require authorization before they are used in food. But GRAS uses sit in an exception lane, and the agency says the law does not explicitly give it authority to require pre-market GRAS submissions.
The agency's own GRAS language separates mandatory food-additive authorization from uses that can reach market without a required pre-market GRAS submission.
GRAS is the exception lane
Some food-chemical uses move through formal FDA authorization. Some move through a self-affirmed or notified GRAS lane.
FDA's GRAS statement says the law does not explicitly require companies to submit GRAS notices before marketing a substance for that use.
Residue compliance is not the same thing as zero exposure
FDA's FY 2023 pesticide monitoring report found that 97.2 percent of domestic human food samples and 86.5 percent of import samples were compliant with federal pesticide residue rules. USDA's 2023 Pesticide Data Program said more than 99 percent of its samples were below EPA benchmark levels.
Those reports describe compliance with legal thresholds, not a residue-free food system.
Post-market cleanup proves the first decision is not always the last
FDA ended 35 PFAS-related food-contact notifications in January 2025 for grease-proofing paper and paperboard uses, revoked BVO in July 2024, and revoked Red No. 3 for food use in January 2025 with a January 2027 food deadline.
Each action came after the substances had already existed inside food or food-contact systems.
The oversight file is fragmented
FDA authorization rules, GRAS exceptions, FDA and USDA residue monitoring, EPA benchmark levels, food-contact notifications, and post-market revocations sit in separate lanes.
The public food-chemical file therefore requires more than one record set: additive rules, GRAS notices, monitoring reports, residue thresholds, and later cleanup actions.
