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.
Sources & records
Reviewed by Standards Review. Updated April 13, 2026.
- FDA Food Chemical Safety
FDA overview of how chemicals enter food through ingredients, packaging, and contamination, including pre-market and post-market activities.
- FDA Additives And GRAS Overview
FDA explanation that food additives require authorization but GRAS uses do not require pre-market review and GRAS notice submission is not mandatory.
- FDA FY 2023 Pesticide Residue Monitoring Report
FDA's current official summary of pesticide residue findings in human and animal foods.
- USDA 2023 Pesticide Data Program Summary
USDA residue-monitoring summary for thousands of domestic and imported food samples, with benchmark-level compliance figures.
- FDA PFAS Food Contact Determination
FDA action ending 35 PFAS-related food contact notifications for grease-proofing paper and paperboard packaging.
- FDA Revokes BVO In Food
FDA's 2024 action revoking the authorization for brominated vegetable oil in food after studies found potential adverse health effects in humans.
- FDA Red No. 3 Phase-Out Letter
FDA letter documenting the January 15, 2027 food deadline after revoking Red No. 3 authorization and encouraging faster removal.
- FDA Post-Market Not-GRAS Inventory
FDA's public inventory of substances it determined are not GRAS for intended food use, with linked memos and enforcement references.
