By Leah Olson, Vice President of Growth Strategy at Bluedog Design, and Cody Wells, Creative Strategy Director at Bluedog Design
Key takeaways:
- Go beyond technical fixes: Regulatory-driven changes, like removing artificial dyes, should be seen not just as compliance tasks but as opportunities to enhance brand experience and align with consumer values.
- Tailor communication to diverse audiences: Brands must thoughtfully navigate consumer reactions by crafting nuanced, transparent messaging that addresses varying levels of awareness and sentiment about product changes.
- Plan proactively and holistically: Anticipate future ingredient scrutiny, assess reformulation trade-offs carefully, and use packaging design strategically to reinforce trust and brand equity amid evolving expectations.
In January of this year, the FDA formally revoked its authorization for the use of FD&C Red No. 3 in food and gave manufacturers until January 15, 2027 to reformulate their products. While no further official bans have occurred, by April, Robert F. Kennedy Jr., the secretary of the Department of Health and Human Services, claimed to have reached “an understanding” with food manufacturers to remove commonly used artificial food dyes from their products by 2026.
Many manufacturers seem to be falling into line voluntarily, under the assumption that official regulations are forthcoming. The Associated Press reported on June 25 that Nestle “will eliminate artificial colors from its U.S. food and beverages by the middle of 2026.” A week prior, Kraft Heinz and General Mills announced they will take similar steps for their U.S. products by 2027. Compliance isn’t everyone’s posture though. Other confectionary focused companies, such as Mars, are holding out for official regulation on the issue.
At Bluedog, as a brand and innovation consultancy with a significant client base in food and beverage, we work with many global brands like those mentioned above. They have told us the FDA’s move will impact dozens and dozens of their products ranging from cakes and candies to snacks and drinks. The Journal of the Academy of Nutrition and Dietetics reported in June that 19% of processed foods make use of synthetic dyes.
The challenges, according to these companies, go well beyond how to replicate a particular color but also retain what consumers love about the products as they are now. When Kraft replaced synthetic colors with spices like turmeric in its “Original Kraft Macaroni & Cheese,” the company had to think about the effect those new ingredients would have on taste as well as supply chain, pricing, and overall brand experience.
For companies and brands navigating an uncertain regulatory environment, trying to figure out what — and how much — to do, here are a few provocations to consider that may help your strategies feel less reactive or even create opportunities to strengthen your brand through its response.
1. Reframe the formula: Go beyond solving technical challenges
While some of our clients say their R&D teams are equipped to handle the technical challenges, there are bigger questions beyond complying with a new directive, particularly when colors and flavors play a significant role in a brand’s equity.
What does the brand stand for with consumers and how will a significant change in the product experience impact that? If, for example, Jell-O isn’t the same lime green color (or flavor profile), what will the experience be like for consumers? When consumers open a brightly colored box and find snacks with a muted version of those colors, how will they react?
Brand managers and executives can choose to see a mandated regulatory change as more than a technical issue to solve by embracing an opportunity to optimize the broader product experience, as these types of changes can impact many points in that experience — from shopping to opening to eating. Or even an opportunity to express a brand’s values in a more visible way.
2. Pivot the message: Speak differently to different consumers
When regulations change a brand’s world, how can it meet consumers where they are? Some will not know why the change happened. Others will be highly aware of the conversation happening around these ingredients and be pleased with the shifts. And still others will be angry the brand did not make the switch much sooner or feel frustrated that they had to be “forced” to do so.
How does a company articulate change with nuance and intention given these different audiences? For many brands, the temptation will be to fly under the radar and attract as little attention as possible. But for those that choose to communicate, there will inevitably be groups of consumers reacting in different ways. Brands can and should try to meet consumers where they are on the issues at hand. A single message issued in a press release will likely not satisfy the assumptions and concerns of these very different groups. Ultimately, a brand should prepare to talk to consumers authentically about not only why it is making a change but also why now.
3. Rethink the pipeline: More product reformulations are coming, fast
Efforts to ban artificial colors tap into consumer demands that have circulated for some time. The onus will be on brands to determine what may be next and use the momentum of pending restrictions to put in place a strategy that gets ahead of more changes to come — and reckons with the reality that there are and will be cases where popular opinion outpaces scientific support for the harms of particular ingredients. Think about artificial flavorings, preservatives, and microplastics. These issues may soon take on a new urgency, but the conversations around them are not new.
But simply removing every possibly problematic ingredient isn’t feasible or even desirable.
For example, carrageenan is a food additive that websites like Healthline note “may cause digestive side effects.” Carrageenan is naturally derived, coming from red seaweed and used as a thickening agent in foods and drinks. Not long ago, fairlife replaced this ingredient with oat fiber in a line of protein beverages. The change satisfied some consumers concerned, in part, by the inflammatory effects of carrageenan. But people who sought a gluten-free beverage found the new ingredient made fairlife a poor choice for their dietary needs for reasons that were different than before.
When reformulating a brand, executives must decide what they are able to live with and which things they are prepared to face criticism on as well as how to address that. There will never be a packaged food industry free from all preservatives, for example, so brands must decide how to right-size and balance the anticipation of consumer or regulatory demands and the potentially unforeseen consequences of doing so, to make the choice that is best for their business.
4. Redesign with intention
If a product is changing, most of its consumers will only receive communication about that change by encountering the product on the shelf. Visual design and communication strategy on pack can be used to strengthen equity and ease understanding in the face of formation changes, Ensuring product photography sets appropriate expectations, making claims work harder for you, taking the opportunity to refresh pack copy — all these should be reconsidered when making formulation changes to ensure a product sets appealing and accurate expectations, and of course delivers on that experience.
Many brands will wrestle with their own response to meet the requirements of the government banning Red No. 3. But leaders do not want to misinterpret the larger reasons for the government’s action. Consumers are educating themselves to a much greater extent than ever before and forming their own opinions about what is going into the food and beverages they consume. Companies can react strictly to comply. Or they can see compliance as the catalyst for a much bigger opportunity to protect and support the health of their brands in the years ahead.
Leah Olson is Vice President of Growth Strategy for Bluedog Design where she and her team create growth and go-to-market strategies, among other initiatives, for publicly traded and privately held firms across CPG. She earned her MBA and bachelor’s degree from the University of Chicago.
Cody Wells is Creative Strategy Director for Bluedog Design where he focuses on innovation, brand strategy, communication strategy, and consumer insights. He received his bachelor’s degree from The Wharton School at the University of Pennsylvania.
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