Smart Snacks, MAHA and Food Dye Bans: A Compliance Guide for Foodservice Directors

Last updated October 20, 2026 (state laws and ingredient lists verified against bill text)

Last updated: October 20, 2026 (state table and ingredient lists re-verified against bill text). This guide summarizes public sources as of that date. Rules in this area change often. Check each source before you act.

Not legal advice. This guide is general information, not legal advice. Whether a rule applies to your operation depends on your state, your programs and your contracts. Confirm with your state agency (for K-12, your state child nutrition agency), your counsel and your contract terms.

The short version

• Binding now for K-12: USDA’s Smart Snacks standards for food sold to students on campus during the school day, and the added-sugar limits on cereal, yogurt and flavored milk in school meals that began July 1, 2025 (USDA).
• Binding next for K-12: On July 1, 2027, school meals must keep added sugars under 10% of weekly calories, and sodium limits drop about 10% at breakfast and 15% at lunch (USDA; USDA sodium table).
• Binding for all food: FDA revoked Red No. 3. Food can’t use it after January 15, 2027 (FDA).
• Voluntary (so far): The federal push to remove Red 40, Yellow 5, Yellow 6, Blue 1, Blue 2 and Green 3 relies on company pledges. FDA has not proposed a ban on them (FDA; Regbase).
• Proposed or in review: A USDA rule to align school meals with the 2025-2030 Dietary Guidelines, and a federal definition of ultra-processed food (reginfo.gov; HHS).
• States are moving faster: Thirteen states have enacted laws restricting dyes or additives in school food. Five are in force as of fall 2026 (see the state table, verified against each bill).

Smart Snacks in School: what it covers

Smart Snacks is the federal standard for “competitive foods”: food and drinks sold to students on the school campus during the school day outside the reimbursable meal. That includes à la carte lines, vending, school stores and in-school fundraisers (USDA). The rule sits at 7 CFR 210.11 (Oklahoma Human Services handbook citing the regulation).

To qualify, a food must first meet a general standard. It must be whole-grain rich, or have a fruit, vegetable, dairy or protein food as its first ingredient, or be a combination food with at least ¼ cup of fruit or vegetable. It must then meet these nutrient limits (USDA, A Guide to Smart Snacks in School):

Fundraisers. Under federal policy there’s no limit on fundraisers that sell non-food items or Smart Snacks-compliant food. The standards also don’t apply to fundraisers held outside school hours, on weekends or off campus. Food meant to be eaten at home, like preordered cookie dough or frozen pizza, is outside the standard too. States set how many exempt in-school fundraisers may sell food that doesn’t meet the standards (USDA; USDA guide). Several state dye laws add their own fundraiser rules, covered in the table below.

School meal standards: the 2024 rule’s phase-in

USDA’s April 2024 final rule (Meal Patterns Consistent With the 2020-2025 Dietary Guidelines) took effect July 1, 2024. Menu changes phase in from school year 2025-26 through 2027-28 (USDA).

Sources: USDA added sugars; USDA sodium limits; USDA rule summary.

What may change. USDA has a proposed rule in the pipeline, RIN 0584-AF17, to adjust meal patterns to the 2025-2030 Dietary Guidelines and simplify operations. The federal regulatory agenda targeted the proposal for September 2026 and a final rule for September 2027 (reginfo.gov). As of this update we found no published proposed rule in the Federal Register. Until a final rule says otherwise, the 2024 dates above remain the requirements on the books.

MAHA: what’s binding and what isn’t

“Make America Healthy Again” is the federal health agenda led by HHS. The MAHA Commission published an assessment in May 2025 (MAHA Report) and a strategy in September 2025 (MAHA Strategy). Commission reports are not regulations. They direct agencies, and agencies then have to use their own rulemaking or guidance.

What has come out of it so far, by status:

By segment, in plain terms: for K-12 and child care, the binding federal rules are still the USDA program rules above. For college, healthcare, senior living and B&I, we found no MAHA action that directly regulates your menus as of this update. What reaches you is FDA’s ingredient rules (Red No. 3 now, others if they come) and any state laws, plus the reformulation suppliers make for everyone. The School Nutrition Association has warned that moving school meals toward MAHA goals will take funding, staff, equipment and time (SNA).

Synthetic food dyes: federal actions

• Red No. 3: FDA revoked its authorization on January 15, 2025, under the Delaney Clause. Objections stayed the order until FDA denied them and lifted the stay on August 5, 2026, which confirmed the deadlines (as reported by Regbase; we didn’t read the Federal Register notice itself). Food can’t use it after January 15, 2027; ingested drugs have until January 18, 2028 (FDA; Regbase).
• Six remaining petroleum-based dyes (Red 40, Yellow 5, Yellow 6, Blue 1, Blue 2, Green 3): HHS and FDA announced a national phase-out on April 22, 2025. It runs on voluntary company commitments. FDA’s page says it is working with industry “to eliminate six remaining certified color additives … by the end of 2027.” Some earlier coverage of the April 2025 announcement cited the end of 2026. They remain federally legal (FDA).
• Orange B: revoked. The final order took effect September 8, 2026 (FDA).
• Citrus Red No. 2: proposed for revocation (FDA).
• “No artificial colors” labeling: In February 2026, FDA guidance allowed the claim on products that dropped petroleum dyes but use natural-source colors (Regbase).

Voluntary industry commitments. FDA keeps a public tracker of company pledges, including commitments aimed specifically at food sold to schools. For example, the American Bakers Association committed to removing certified colors from baked goods provided to K-12 programs by the start of the 2026-27 school year (FDA tracker). Many entries are still marked “in progress.” Treat a pledge as a reason to ask your supplier, not as proof that a product is compliant.

State laws on dyes and additives in school food (enacted)

This table lists enacted laws only. “K-12” means the law applies to school food, not to all food sold in the state. Scope varies a lot: some laws cover only reimbursable breakfast and lunch, others cover everything sold on campus during the school day. Each row links to the official legislature page or enrolled text, which we read directly. Read the text yourself before acting.

The “What’s restricted” column lists every substance each law names. Dyes are FD&C color additives (for example, Red No. 40 is FD&C Red No. 40). Ingredient lists were checked against the bill or statute text on Oct. 20, 2026.

Not verified from a primary source: Tennessee’s 2025 Red 40-only law, which SB 2423 expanded, is not in this table. We didn’t read its text.

Pending, not law (as of Oct. 19, 2026):

• New York S1239-F / A1556-G would ban FD&C Red No. 3, potassium bromate and propylparaben in all food statewide, and add GRAS reporting. The Senate repassed it Mar. 23, 2026 and the Assembly passed it Apr. 21, 2026. The official record shows no delivery to the governor. If signed, the act takes effect one year after it becomes law (NY Assembly bill record).
• Michigan HB 5069 would prohibit BVO, propylparaben, Red 40, Green 3, Blue 1, Blue 2 and Yellow 6 in food statewide. It passed the House June 17, 2026 (56-51) and was referred to the Senate Regulatory Affairs Committee June 23, 2026 (Michigan Legislature; House-passed text).
• Many more bills were filed: one count found more than 140 additive bills in 38 states in 2025 (MultiState).

Not a statute, but relevant: Texas’s attorney general reached commitments with two cereal makers to remove dyes from K-12 cereals, and Florida’s attorney general opened a consumer-protection investigation into potassium bromate in July 2026 (Regbase).

What directors should do now

1. Map your rules (this month)

• List every state you operate in and pull that state’s law and agency guidance from the table above.
• For each one, note what’s covered: reimbursable meals only, or à la carte, vending, catering, concessions and fundraisers too.
• Diary the dates: Jan. 1, 2027 (California AB 418), Jan. 15, 2027 (federal Red No. 3), July 1, 2027 (USDA added-sugar weekly limit and sodium cut), and your state’s school dye date.

2. Review vendors and specs

• Ask each distributor and manufacturer for a written list of items containing the dyes and additives your state names, with planned reformulation dates.
• Ask for current spec sheets and ingredient statements, not marketing claims. “Dye-free” pledges don’t always cover every SKU or every channel.
• Flag commodity (USDA Foods) items as well as commercial purchases.

3. Audit menus and à la carte

• Run your item list against the dye and additive list plus Smart Snacks limits. Usual suspects: candy, frosted or colored baked goods, cereals, sports drinks, flavored drinks, gelatin, sauces, sprinkles and toppings.
• Check flavored milk, yogurt and cereal against the added-sugar limits that started in 2025.
• Run a sodium analysis against the July 2027 limits now. A 15% cut at lunch usually needs recipe work, not just swaps.

4. Update bid and contract language

• Add a clause requiring that products comply with federal and state ingredient restrictions in force during the contract term, including those with later effective dates.
• Require notice of reformulation, substitution rules and a compliant-product guarantee. Ask for ingredient change alerts.
• Texas’s law applies to contracts for free and reduced-price meals entered or renewed on or after Sept. 1, 2026 (SB 314). Tennessee’s applies to contracts entered on or after Aug. 1, 2027 (SB 2423). Check renewal timing.
• Have counsel or your state agency review new language before you use it.

5. Plan student and family communication

• Tell students and families what’s changing before it hits the line. Colors may look softer and textures slightly different; one Texas district published a simple “what you may notice” table (Sherman ISD).
• Use taste tests and student panels for replacement items. Track participation and plate waste through the switch.
• Tell PTAs, booster clubs and teachers what the rules mean for fundraisers, classroom treats and events.

6. Set a timeline

• Now to Dec. 2026: inventory, vendor letters, menu audit, Red No. 3 cleared from stock before Jan. 15, 2027.
• Spring 2027 bid cycle: new spec language. Tennessee’s law and Texas’s law tie to contract dates, so check renewals and product approvals for SY 2027-28.
• By July 1, 2027: sodium and added-sugar menus finalized; Virginia (July 1, 2027) and Iowa (SY 2027-28) dye rules met. Tennessee and Nebraska follow on Aug. 1, 2027.
• Ongoing: watch for USDA’s proposed school meal rule and your state legislature’s next session.

Notes by segment

K-12. This is where nearly all the binding rules land: Smart Snacks, the 2024 meal pattern phase-in, and state school dye laws. Your state child nutrition agency is the authority on how these apply to your programs. Scope varies: Texas covers only free and reduced-price meals (SB 314), Nebraska only reimbursable meals (LB 940), while Iowa reaches on-campus sales during the school day (HF 2676).

College and university. State school dye laws in the table above apply to K-12, not higher education. The Red No. 3 deadline and California’s AB 418 apply to all food, so campus retail, c-stores and vending are affected. Expect students and parents to ask about dyes even where no rule applies.

Healthcare. We found no MAHA action as of this update that directly sets hospital patient or retail menus. The federal Red No. 3 deadline and state all-food laws (California AB 418) still apply to what you buy. Supplier reformulation will change products whether or not a rule targets you.

Senior living. Same as healthcare: no MAHA rule found that directly governs senior living menus as of this update. Ingredient rules for all food apply. If you run programs with federal nutrition requirements, check with the administering agency whether the 2025-2030 Dietary Guidelines change your program rules.

Business & industry. Food service at work isn’t covered by school laws. Red No. 3 and California AB 418 apply. Clients with wellness goals may ask for dye-free or lower-sugar options. Update specs so you aren’t left with noncompliant stock in California after Jan. 1, 2027.

FAQ

Is Red 40 banned in the U.S.? Not federally. FDA hasn’t proposed a rule to ban Red 40 or the other five remaining petroleum-based dyes; the phase-out is voluntary. Several states restrict Red 40 in school food (FDA; Regbase).

When does the Red No. 3 ban take effect? For food, January 15, 2027. FDA confirmed that date when it lifted the stay on August 5, 2026 (FDA; Regbase).

Do Smart Snacks rules apply to fundraisers? They apply to food sold to students on campus during the school day, including fundraisers. States decide how many exempt fundraisers are allowed. After-school, weekend, off-campus and take-home sales aren’t covered by the federal rule, though local or state rules may be (USDA).

Are MAHA recommendations legally binding on school meals? Not by themselves. The MAHA reports and the 2025-2030 Dietary Guidelines change school meal rules only when USDA updates them through rulemaking. That rule was still at the proposed stage as of this update (reginfo.gov).

What are the new added-sugar limits for school meals? Since July 1, 2025: cereal ≤6 g per dry ounce, yogurt ≤12 g per 6 oz, flavored milk ≤10 g per 8 fl oz. From July 1, 2027: under 10% of weekly calories from added sugars (USDA).

Which states ban food dyes in schools? As of this update, 13 states have enacted laws: West Virginia, Delaware, Utah, Arizona and Texas (in force), plus Virginia, California, Iowa, Tennessee, Nebraska, Alaska, New Hampshire and Louisiana (later dates). See the table above, which links each bill.

Do state school dye bans apply to colleges or hospitals? The school laws in the table apply to K-12 schools. All-food laws, like California AB 418 and the federal Red No. 3 revocation, apply to every segment (Regbase).

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