While there are numerous pathways for companies to bring substances intended for use in or in contact with human food to market, a recent directive from the U.S. Department of Health and Human Services (HHS) to the U.S. Food and Drug Administration (FDA) to begin rulemaking could result in changes to the generally recognized as safe (GRAS) pathway that will impact the food and beverage industry. Beyond FDA, we’ve also seen state action aimed at reforming the GRAS pathway.