Regulatory deadlines are becoming plant deadlines

The Food and Drug Administration revoked authorization for FD&C Red No. 3 in food and ingested drugs in January 2025. Food manufacturers have until Jan. 15, 2027, to reformulate products that use the dye. The FDA and the U.S. Department of Health and Human Services have announced initiatives intended to accelerate the reduction of petroleum-based synthetic dyes in the food and beverage supply while expanding the availability of natural-source color alternatives. Retailers are setting their own timetables. Some private-brand programs are targeting January 2027 for synthetic dye removal, while other retail assortment changes have been tied to 2026 certified-color deadlines.

For beverage suppliers, those dates can compress the time available for formulation, qualification, capital planning and plant upgrades. The technical work might start in the lab, but the deadline often lands in receiving, storage, batching, sanitation and filling.

Color matters in beverages because it shapes a consumer’s expectation before the first sip. A change in shade can raise questions about flavor, quality or freshness, even when the formula still meets the brand’s sensory target. Beverage teams need a formula that works in the bottle, can or carton. They also need a plant that can run that formula at the required rate.

Natural colors change material handling

Synthetic colors have long been favored in beverage production because they are highly concentrated, consistent and relatively easy to work with across a range of manufacturing conditions. Natural colors can also perform well, but they often require different handling and processing considerations. Depending on the formulation, manufacturers may need to adjust ingredient management, production practices or quality controls to maintain consistent product performance.

One of the first areas affected by a color change is ingredient receiving and storage. Natural colors often have different handling requirements than synthetic alternatives, which can influence how ingredients are stored, transferred and managed throughout the facility. As a result, manufacturers might need to evaluate whether existing storage systems and operating practices can support the new ingredient.

Formulation changes can affect facility operations as much as the ingredient itself. When a natural color requires different usage rates or handling practices than the synthetic color it replaces, the impacts can extend across inventory management, production processes and quality programs. Understanding these downstream effects early can help manufacturers avoid operational disruptions during reformulation.

The impact of a color change will vary by product and process. What works for one beverage might create different operational considerations for another, depending on its formulation and manufacturing requirements. Rather than applying a one-size-fits-all approach, manufacturers should evaluate how each reformulation affects the facility systems and processes needed to produce the product consistently and at scale.

Batching and sanitation may require new operating practices

Batching is often where a formulation change becomes an operational change. A natural color might need to be added at a different point in the sequence to limit heat exposure or improve dispersion. It might require a different mixing profile, more controlled hydration or tighter pH management. In the case of a carbonated product, assessing color behavior might need to occur before and after carbonation. 

Sanitation can change as well. A dye that behaves predictably in a bench formulation may leave residue, stain equipment or require a different clean-in-place cycle at production scale. Liquid natural ingredients can introduce additional microbiological considerations. Powders can build up in feeders, hoppers or transfer points. If a facility runs legacy and reformulated products on the same line, changeover sequencing becomes more important because a small amount of carryover can affect shade, label claims or customer specifications.

Throughput depends on more than the formula

Throughput risk connects these issues. A beverage facility might be able to make a successful pilot batch and then struggle when the same formula moves through normal production windows, staffing levels and sanitation schedules. Higher ingredient volumes, longer dispersion times, additional quality checks, altered thermal profiles or longer cleanups can reduce line availability.

Those impacts are easy to underestimate. A few extra minutes for each batch might not appear material during a trial, but that time matters on a line supporting seasonal demand or tight customer commitments. More material movement can affect labor planning. Added quality holds can affect tank turns. Longer cleaning cycles can affect the next product in the schedule. The operational question is not only whether the beverage can match the target color. It is whether the plant can produce that color under commercial constraints day after day.

Packaging decisions might need another look. If a natural color is more vulnerable to light or oxygen, bottle material, label coverage, secondary packaging, warehouse conditions and distribution practices can affect shelf-life performance. Clear bottles create a different risk profile than cans, cartons or opaque packaging. Product development, packaging engineering and shelf-life testing should be connected early enough to avoid late-stage surprises.

Beverage manufacturers face an additional challenge because color performance must remain acceptable throughout the product’s shelf life, not simply at the time of filling. Natural dyes may respond differently to temperature fluctuations, light exposure and oxygen ingress during storage and distribution. As a result, shelf-life validation becomes an important part of the commercialization process. Because the liquid itself remains visible to the consumer, even minor color shifts can become noticeable in clear packaging formats, making shelf-life performance and package selection closely linked.

Even a formula that performs well in internal testing might need sign-off from retailers, foodservice customers or brand owners before it can ship. If the color of the reformulated product falls outside an existing appearance specification, manufacturers will need to go through a requalification process before the product can move.

Designing and constructing for flexibility

An early facility assessment can help beverage manufacturers understand where a formula change creates operating or capital needs. The review should look beyond the ingredient deck and evaluate how the new color affects ingredient handling and storage, processing equipment and utilities, sanitation and wastewater systems, quality and regulatory requirements, packaging operations, and available space for temporary or modular equipment.

An effective assessment looks beyond technical requirements and considers how changes will actually be executed. Reformulation deadlines rarely align with long equipment lead times, permitting processes or available outage windows. Early collaboration among product development, quality, operations, procurement, engineering and construction teams can help prioritize the most critical facility modifications and develop a phased implementation plan that supports both production continuity and project schedules.

Integrated engineering, procurement and construction delivery can support this work when design and field execution need to move in parallel. In some cases, modular skids, prefabricated utility assemblies, temporary storage or phased tie-ins can help facilities add capability while limiting disruption to active production. The value is not only speed. It is the ability to align technical decisions with schedule, constructability and plant access before a deadline becomes a line constraint.

The goal should not be to solve for one natural color or one regulatory deadline. FDA approvals of natural-source color options and retailer specifications will continue to change. Ingredient availability and color technologies also will shift. A facility that can handle multiple ingredient formats, protect temperature-sensitive materials, adjust addition points and preserve line uptime will be better prepared for the next formulation change.

Natural color conversion is a visible consumer-facing change, but much of the work is invisible to the consumer. Beverage manufacturers that treat the transition as a cross-functional operations and capital program can protect product quality while reducing production disruption. The work starts with color, but success depends on how well the whole facility is prepared to run the new formulation.