The Colour Swap Is the Easy Part. Who’s Actually Going to Do It?

Many of the biggest food companies are now working to remove synthetic colours on overlapping 2026 and 2027 timelines. Far fewer have worked out who’s going to do the work. And almost nobody’s noticed they’re all reaching into the same small drawer at once.

An R&D director I’ve known for years put it plainly on a call last month.

“Getting the dyes out isn’t what keeps me up. It’s that half my industry is about to want the same three people to do it, and I employ one of them.”

Overlapping deadlines. One small pool of people who’ve actually done this. Every competitor reaching in at the same moment.

That’s the part of the reformulation story that the headlines keep skating over, and it’s the part that lands on a leadership team long before it troubles a lab.

The deadline is real, even where the rule isn’t

Let me clear up where things actually stand, because the coverage has muddied it.

In April 2025, the US Department of Health and Human Services and the FDA announced a plan to work with industry to phase petroleum-based synthetic dyes out of the food supply.

The original headline target for the main six — Red 40, Yellow 5, Yellow 6, Blue 1, Blue 2 and Green 3 — was the end of 2026. Subsequent industry commitments have largely settled around 2027, which is also the date now used on the FDA’s industry tracker.

Here’s the nuance that decides how you plan.

Nobody signed anything. Kennedy called it an understanding between the FDA and the manufacturers, and an understanding is all it is. No rulemaking was completed, no food manufacturer was present at the announcement, and the six dyes remain legal to use. Under current federal law, continuing to use Red 40 after the end of 2027 would not, by itself, violate a federal ban, because no such ban has yet been adopted.

Red No. 3 is the exception, and it’s the one with teeth. The FDA revoked its authorisation in January 2025 under the Delaney Clause, which leaves the agency no discretion once an additive is shown to cause cancer in animals, even though the FDA says the rat-specific mechanism does not occur in humans and that the available evidence does not support a human safety risk. Food has to be reformulated by 15 January 2027.

So a lawyer will tell you, correctly, that most of this is still voluntary. And a category director will tell you, just as correctly, that it makes no difference to the day job.

California, Utah, Virginia, West Virginia and other states have enacted restrictions affecting synthetic dyes in school food, each with its own scope, exceptions and timetable. Texas went a different way, requiring warning labels on products containing any of forty-four listed ingredients, though a federal court blocked that requirement in February 2026 and the state has appealed. West Virginia also enacted a broader statewide sales prohibition due to take effect in January 2028, but a federal court preliminarily blocked its enforcement in December 2025 while litigation continues. Its school-meal restrictions were not blocked and remain in force. Dozens more states introduced bills through 2025. None of that makes planning simpler. It means the map moves under you, and somebody in your business has to be tracking it.

Major retailers and manufacturers have moved too, with Walmart removing synthetic colours and 30 additional ingredients from its US private-label foods, and Kraft Heinz committing to remove remaining FD&C colours from its US portfolio.

When the shelf sets the rule, the rule is set.

This is a major reformulation wave for the US food industry. And many of its biggest businesses are now working to overlapping 2026 and 2027 timelines.

“Just swap to natural” is doing a lot of lying

Anyone who’s run this work knows how much that phrase hides.

Synthetic dyes have held their ground for a century because the chemistry is genuinely hard to beat. Raw botanical sources may contain less than two per cent pigment, while synthesised pure dyes can exceed ninety per cent. Even after extraction, commercial natural colours generally have lower pigment loads and may require considerably higher usage rates to achieve and maintain the same shade. That’s before anyone checks whether the colour survives the process. Natural colours shift with pH. They fade under processing and light. They behave one way in a still drink and another in a hot-filled sauce. And they lean on agricultural supply chains that answer to harvests and weather rather than to your production plan. Sensient, one of the larger colour houses, tells brands converting from synthetic to expect an average cost increase of eight to ten times. Its chief executive, Paul Manning, puts the same range on the full synthetic portfolio, with reds, blues and greens reaching twenty depending on the shade and the application.

None of which makes it impossible. Nestlé USA said in June 2026 that it had cleared FD&C colours out of its entire US food and beverage portfolio, its foodservice teams moving more than twenty Vitality beverages onto natural sources in around five months without compromising quality or taste. It gets done, and done well.

But you can raise a purchase order for the pigment. You can’t raise one for the person who knows how it behaves through your process.

The line item nobody costed

Every board I speak to has a reformulation plan. Timelines, target SKUs, supplier conversations, a capex number. What far fewer of them have is a plan for the people who turn that into shipped product.

That’s the gap. The industry has read this as a technical and procurement problem, which it is, and walked straight past the fact that technical and procurement problems get solved by specific, nameable people who happen to be in short supply.

Picture who a serious colour reformulation actually needs.

It needs applications and R&D leaders who’ve taken natural colour systems through real product, on a real line, at volume. Not once, in a trial, but as a programme. It needs regulatory affairs leaders who can hold a voluntary federal policy, enforceable Red No. 3 requirements, a patchwork of state law and the FDA’s February 2026 opening on “no artificial colours” claims in the same head, and tell the business, cleanly, what goes on which label in which state. And it needs procurement and supply leaders who can lock down fragile natural-colour supply before the rest of the market wakes up and tries to do the same.

Those people exist. They’re just not waiting by the phone. In the market I see, many already sit inside competitors, and the sharper businesses have quietly started trying to retain them.

Overlapping deadlines don’t create nine separate hiring markets. They create one queue.

Here’s the pattern I’ve watched in every talent-short moment this sector has thrown up.

A business waits until the need is undeniable, then goes to market at the precise moment everyone else does. The good people are already three conversations deep with someone quicker off the mark. Whoever’s left costs more by the week. What felt like sensible timing turns out to be the most expensive way to hire there is.

The dye transition sharpens that to a point, for one plain reason. The clock is shared. The largest US manufacturers and retailers are working toward overlapping 2026 and 2027 dates, and the Consumer Brands Association has urged its member companies, whose brands number in the thousands, to stop manufacturing with FD&C colours by the end of 2027. Demand for the same narrow band of people converges into the same narrow window. That isn’t a tight market. That’s a run on a very small bank.

The companies that come through this well won’t be the ones with the slickest reformulation deck. They’ll be the ones who worked out early which two or three capabilities they couldn’t do this without, and got to them before the rush.

There’s a quieter version of this for the investors reading, too. Plenty of value-creation plans lean on a portfolio that’s “moving to clean label.” The reformulation gets modelled. The people who deliver it rarely do. Worth asking, of any business banking on that shift, whether anyone’s actually costed the talent to make it happen, or whether the plan just assumes the right hands are already on the payroll.

Questions worth putting on the table

If you run, back, or sit on the board of a business selling into these markets, a few questions are worth raising this quarter. Not after the next deadline bites.

Have we named the roles, or just approved the project?

“We need R&D support” is not a plan. The specific leadership capability that decides whether your programme lands on time is usually a small number of hard-to-find people, and it’s usually never been written down.

Do we actually have them, or only think we do?

Plenty of teams are strong at innovation in the abstract and have never run a reformulation of this scale against a hard date. That’s a different muscle, and the deadline is a poor time to discover which one you’ve got.

Are we hiring ahead of the market, or into it?

That single choice sets both what these people cost you and whether they’re available to be hired at all.

The real test

The reformulations will get done. The labels will get changed. They usually do.

The harder question sits above all of that, and it’s the one most boards haven’t said out loud yet. When companies across your category reach into the same small drawer at the same time, who did you make sure was already yours?

If you can’t answer that cleanly, it deserves more of your attention than the next rule change. The regulatory and market pressure is moving either way. Whether someone’s ready to deliver against it is the part still in your hands.

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This is part of my “Behind the Scenes” series, where I share what I’m picking up from conversations with the leaders, founders and operators shaping the future of food. If something here landed, I’d like to hear how you’re seeing it.

Mike Meyrick is Founder and CEO of Meyrick Consulting, an international executive search firm operating across the food and food ingredients sector.