• FDA announced on Tuesday, June 24, 2025, that it has updated Compliance Program 7321.005, now titled General Food Labeling Requirements and Labeling-Related Sample-Analysis – Domestic and Import. This updated Compliance Program (CP) includes guidelines and procedures that the FDA uses for both domestic and overseas inspections of food facilities.
  • The major changes were summarized by FDA as “incorporation of sesame as the ninth major food allergen” and “guidance on gluten-free labeling requirements.” The CP also includes nutrient declaration changes to make the document align with the updated Nutrient Facts Label. A more extensive list of updates can be found on page 4 of the Compliance Program.
  • The updated CP has been heavily edited throughout, both in terms of its text and formatting. The document was originally 33 pages long in total; the updated version is now almost twice as long at 61 pages.
  • Keller and Heckman will continue to monitor FDA regulatory changes related to food labeling.