New regulations may accelerate shift to clean label

KANSAS CITY — Baked foods companies increasingly are taking the clean label route and turning to ingredients seen as natural to reformulate products.

Soon, their options on traditional ingredients with more chemical-sounding names may decrease. Actions from the US Food and Drug Administration, the American Bakers Association and the state of California are taking aim at phasing out ingredients such as butylated hydroxyanisole (BHA), azodicarbonamide (ADA) and synthetic colors.

California in 2023 passed a law to ban the sale of foods and beverages containing Red No. 3, brominated vegetable oil, potassium bromate or propylparaben in the state beginning Jan. 1, 2027. What ingredients might the state target next? Possibilities might be found in California’s Proposition 65.

Officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986, Proposition 65 protects the state’s drinking water sources from being contaminated with chemicals known to cause cancer, birth defects or other reproductive harm. The law requires businesses to inform Californians about exposure to such chemicals.

Baked foods may contain “very small amounts” of compounds on the Proposition 65 list, said Troy Boutte, PhD, vice president of innovation for AB Mauri North America, St. Louis.

Boutte gave examples of a bread or cake likely containing traces of sulfur dioxide, often used on fruit to prevent browning, and acrylamide, formed via the Maillard reaction during the baking or heating of food. Sulfur dioxide in fruit could be replaced by switching to a frozen fruit, he said.

Potassium bromate, used as a dough conditioner to improve baked volume, and silicon dioxide, used as a flow agent, also are listed in Proposition 65, said Jose Nolasco, research and development manager for J&K Ingredients, Paterson, NJ. Calcium carbonate or powdered fibers like rice hulls may replace silicon dioxide.

Bromate is particularly effective in retarded dough systems that require high tolerance for extended fermentation periods, said Ashley Beech, bakery product development manager for Corbion, whose North American headquarters is in Lenexa, Kan.

“Although bromate has been used commercially since the 1920s, it has recently faced increased scrutiny due to evolving regulatory pressures and ingredient transparency concerns, including measures such as Proposition 65,” she said. “As a result, many millers and bakers are actively seeking bromate-free flours.”

Potassium bromate and butylated hydroxyanisole (BHA) are two baking ingredients of note found in California’s Proposition 65, said Ben Reusser, innovation center manager for Cain Food Industries, Dallas. Potassium bromate, an oxidizing agent, is used to strengthen dough in bread and rolls.

“Potassium bromate can be replaced by alternative dough-strengthening and oxidizing agents, such as ascorbic acid,” he said. “Other options include enzymes that enhance gluten structure or improve dough handling, such as phospholipases for emulsification and glucose oxidase for strengthening gluten. In some formulations, additional vital wheat gluten can also be used to achieve similar functional performance.”

Bye, bye, bha?

In February, the FDA said it is assessing BHA and issued a request for information (RFI) on its use and safety. The agency listed BHA as generally recognized as safe (GRAS) in 1958 and approved it as a food additive in 1961, but the National Institutes of Health’s National Toxicology Program lists BHA as “reasonably anticipated to be a human carcinogen.”

“BHA, or butylated hydroxyanisole, is an antioxidant used to slow oxidation of fats and oils, which in turn slows development of rancidity,” Boutte said. “It is rarely added directly to baked goods but sometimes makes its way onto the labels of baked goods via oils or fats that are added.”

BHA often is combined with butylated hydroxytoluene (BHT), but the total concentration typically does not exceed 200 parts per million (ppm) of the fat content, said My Troung, senior scientist for antioxidants for Corbion.

“While BHA is not directly approved for use in baked goods, it is permitted for use in certain food ingredients, such as emulsion stabilizers for shortenings,” she said. “These treated shortenings can then be used in the production of baked goods, helping maintain freshness and appeal.”

BHA often is used in items containing shortening, margarine or fat-based emulsifiers that require extended shelf life, Nolasco said. These products typically are packaged bakery items like croissants and danish, snacks like crackers and chips, or breakfast food like cereal and cereal bars.

“Depending on the application, BHA can be replaced by natural antioxidants like rosemary extract, alpha-tocopherol (vitamin E) and ascorbic acid (vitamin C),” Nolasco said.

A range of antioxidants used in fats and oils may replace BHA.

“Over the past two decades, there has been a trend toward using friendlier antioxidants such as ascorbic acid, tocopherols and even ingredients like rosemary extract,” Boutte said. “Also, there has been a switch toward oils that are simply more oxidatively stable in the first place, like high-oleic oils.”

Subway removed azodicarbonamide (ADA) from its bread dough over a decade ago.

| Photo: ©RAFAEL BEN-ARI – STOCK.ADOBE.COM

Other materials besides BHA may be blended into fats, Reusser said. They include tocopherols (with vitamin E as an example), which is an antioxidant, and citric acid. Ascorbyl palmitate, another antioxidant, may be added to fats.

Mixed tocopherols, a form of vitamin E, are highly effective at slowing lipid oxidation and preventing rancidity in high-fat products. Ascorbic acid, or vitamin C, not only enhances dough quality but also improves stability during baking. Additionally, green tea extract, known for its high polyphenol content, offers robust antioxidant protection. However, its naturally bitter taste makes it more suitable for savory applications where it can add depth of flavor.

Adios, ada?

The American Bakers Association, Washington, expects to fully phase out the use of azodicarbonamide (ADA) in baked foods by the end of this year, calling the voluntary effort the “baked goods ingredient pledge.”

A 2025 survey found that nearly 95% of ABA member company respondents said they already do not use ADA in their baked foods. Interest in replacing ADA gained steam in 2014, when Subway began removing it from all of its bread dough.

ADA, an oxidant, causes formation of disulfide bonds in bakery dough, which gives dough the strength needed to withstand processing, achieve acceptable baked volume and improve crumb structure, Boutte said. Several possible alternatives to ADA are available for baked foods.

“Since ADA is typically used at low ppm levels and does not add much to cost, usually the addition of oxidative enzymes such as glucose oxidase in combination with ascorbic acid is a good first choice,” he said. “But any dough improver that improves strength is an option, including other enzymes, vital wheat gluten, lecithin, hydrocolloids and combinations of these.”

Reusser said, “ADA is a rapid oxidizing agent used to strengthen the disulfide bonds in the gluten network of dough, providing a stronger dough more tolerant to processing. Ascorbic acid provides a similar function to ADA, and there are enzymes called glucose oxidases that also help in the creation of disulfide bonds in doughs.”

When used as a dough conditioner in bread processing, ADA has been shown to enhance machinability, improve baked bread texture and increase loaf volume, Nolasco said.

“Though there is no perfect alternative to the functionality of ADA, ascorbic acid or glucose oxidase may be used with a blend of softening enzymes like alpha amylase in conjunction with changes to the production process,” he said.

ADA may be incorporated into flour as a bleaching or artificial aging agent, Beech said. It has a regulatory limit of 45 ppm.

“When considering alternatives to ADA, bakers should first identify the specific functionality they wish to replicate,” Beech said. “For bleaching, options include certain enzymes and enzyme-active soy flours. There are numerous alternatives for dough conditioning and enhancing dough strength, such as emulsifiers, oxidizing agents and enzyme blends, which can improve both strength and process tolerance.”

Farewell, FD&C colors?

In November 2025, the ABA issued its “baked goods FD&C colors pledge,” a voluntary industry commitment to eliminate certified FD&C colors from baked foods nationwide. More than 90% of ABA member companies at that time already had committed to eliminating certified FD&C colors by Dec. 31, 2028.

Natural alternatives for coloring include plant-based powders, juices, and concentrates derived from fruit, vegetables, seeds, herbs and spices, Beech said.

“Bakers should consult their regulatory teams to ensure the suitability of these natural colors, as some may be permitted only in specific applications,” she said. “It’s also important to note that natural colors can be sensitive to heat and may react to pH shifts. For instance, anthocyanins can change from red to purple/pink to blue, depending on the product’s pH.

“Additionally, certain colors derived from spices or seeds can impart flavors, which can be an issue in sweet goods but advantageous for savory baked goods.”

Multinational companies began speeding up their efforts to replace FD&C colors after the US Department of Health and Human Services, which includes the FDA, in April 2025 said it intended to phase out all petroleum-based synthetic dyes from the nation’s food supply.

A 2025 survey from the International Food Information Council found that 12% of respondents consider food additives and ingredients (caffeine, monosodium glutamate, flavors, colors and preservatives) as their most important issue in food safety, which was up from 6% in the 2024 survey. Another 24% of those polled ranked food additives and ingredients as either No. 2 or No. 3.

Enzymes for clean label

Enzymes assist in plenty of clean label solutions for food.

“Enzymes are a great way to achieve a cleaner label in baked goods,” Beech said. “Enzymes allow bakers to leverage naturally occurring compounds in dough to accelerate key processes, enabling bakers to optimize performance more efficiently. By incorporating enzymes, manufacturers can reduce and even replace synthetic ingredients while maintaining product quality.”

Reusser spoke highly of the use of enzymes as well.

“Enzyme systems and ascorbic acid enable the removal of traditional emulsifiers such as DATEM, SSL, ADA and potassium bromate — without sacrificing dough strength or processing tolerance,” he said. “Additionally, functional ingredients like tocopherols help protect against oxidative rancidity, preserving flavor and quality over time.”