FDA's New Chemical Ranking System Could Remove BHT, BHA, and ADA From Your Food

On June 18, 2025, the FDA released a proposed method that could fundamentally change how food chemicals are regulated in the United States. The "Post-Market Assessment Prioritization Tool" introduces a systematic, science-based approach to ranking chemicals already in the food supply—potentially removing additives that have been on shelves for decades without comprehensive review.

The tool represents a dramatic departure from the FDA's traditional "innocent until proven guilty" approach. For the first time, the agency will proactively assess chemicals using Multi-Criteria Decision Analysis (MCDA), a methodology that assigns scores based on potential health risks and public concern. Higher scores mean higher priority for review—and potential removal from food products.

Among the first chemicals flagged for assessment: BHT, BHA, and azodicarbonamide (ADA)—preservatives and processing agents found in everything from breakfast cereal to sandwich bread.

How the New Ranking System Works

The FDA's new tool uses Multi-Criteria Decision Analysis, a decision-making framework that evaluates options against multiple weighted criteria. In this case, chemicals receive scores across two main categories:

Public Health Criteria assess the potential risks to consumers based on:

• Toxicity data from scientific studies
• Levels of consumer exposure through food
• Impact on vulnerable populations including children, pregnant women, and the elderly

Decisional Criteria incorporate broader factors:

• Public concern and consumer awareness
• Patterns of exposure across different populations
• Availability of safer alternatives

The scoring system produces a transparent ranking: chemicals with higher total scores receive priority for post-market assessment. This systematic approach eliminates the need for individual petitions or public pressure campaigns to trigger FDA review.

"This tool provides a transparent, systematic, science-based approach," the FDA stated in its announcement. Legal analysts at Morrison Foerster characterized the shift as moving from "reactive, case-by-case assessments" to "systematic post-market reviews."

The First Three Targets: BHT, BHA, and ADA

The FDA has identified three widely used food additives as initial candidates for review under the new process:

BHT (Butylated Hydroxytoluene)

BHT is a synthetic antioxidant preservative found in cereals, chewing gum, potato chips, and vegetable oils. It prevents fats from going rancid, extending shelf life. However, research has raised concerns about potential endocrine disruption and possible carcinogenic effects at high doses. BHT is already banned or restricted in several countries, though it remains widely used in U.S. processed foods.

BHA (Butylated Hydroxyanisole)

BHA serves similar preservative functions in snack foods, chewing gum, cereals, and food packaging materials. The National Toxicology Program classifies BHA as "reasonably anticipated to be a human carcinogen." The European Union and United Kingdom have already banned its use in food, yet American consumers continue to encounter it in everyday products.

ADA (Azodicarbonamide)

Azodicarbonamide functions as both a flour bleaching agent and dough conditioner in breads, cereals, and pasta. When inhaled, it's a known respiratory toxin linked to asthma—raising questions about its safety even when consumed. The European Union, Australia, and several other countries have banned ADA from food products. Its presence in U.S. bread has generated consumer backlash in recent years, with some chains voluntarily removing it.

Together, these three chemicals appear in thousands of everyday products consumed by millions of Americans. Their potential restriction or removal would significantly impact both consumer health and food manufacturing practices.

A New Era of Food Chemical Oversight

The FDA's new approach aligns with broader "Make America Healthy Again" priorities under Health and Human Services Secretary Robert F. Kennedy Jr. The tool is part of a larger pattern of regulatory activity in 2025 aimed at reducing toxic food additives.

This shift addresses a long-standing criticism of U.S. food safety regulation. Traditionally, the FDA has operated reactively—reviewing additives primarily when specific concerns are raised rather than systematically monitoring chemicals already on the market. This approach allowed thousands of chemicals to remain in the food supply with limited ongoing oversight.

The new tool changes the equation by:

• Creating a standardized, transparent methodology for prioritization
• Incorporating surveillance and signal detection techniques to identify candidates
• Allowing systematic assessment rather than waiting for petitions or crises
• Producing publicly understandable rankings based on scientific criteria

Timeline and What Happens Next

The FDA's proposed method went through a public comment period that closed on July 18, 2025. The agency is now submitting the method and all public comments for evaluation by external scientific experts.

Date	Milestone
June 18, 2025	FDA releases proposed method for public comment
July 18, 2025	Public comment period closes
Post-July 2025	External scientific expert evaluation begins
TBD	Final methodology implementation

Once the tool is finalized, the FDA will apply it to rank chemicals already in the food supply. Those receiving high scores will undergo post-market assessment, which could lead to restrictions, removal requirements, or determinations that continued use is safe.

Industry experts expect changes could begin taking effect within 1-2 years after the tool is finalized. Consumers may see ingredient changes in cereals, breads, and snack foods as manufacturers anticipate or respond to FDA actions.

The Broader Context: States Are Already Acting

While the federal government develops its new approach, states are not waiting. In 2025 alone, 21 state legislatures introduced food chemical restriction legislation.

Texas took the most aggressive step with SB 25, the "Make Texas Healthy Again" bill signed on June 22, 2025. It requires warning labels on foods containing 44 specified chemicals—including many still permitted under federal law. This creates a patchwork of state regulations that food manufacturers must navigate.

The U.S. also lags behind international standards. The European Union has already banned BHA, ADA, and many other additives still permitted in American foods. The United Kingdom, Australia, and Canada generally maintain more restrictive standards on food additive approvals.

What This Means for Consumers

For consumers, the FDA's new tool represents a potential shift toward greater transparency and safety in the food supply. Key implications include:

Ingredient Changes Coming: Products containing BHT, BHA, and ADA may see reformulations as manufacturers respond to regulatory pressure or voluntary market shifts.

Label Awareness Matters: Consumers concerned about these additives should check labels for "BHT," "BHA," or "azodicarbonamide" in ingredient lists. They commonly appear in cereals, breads, snack foods, and processed items.

Timeline Expectations: While the tool is promising, actual removal of specific chemicals could take months or years after the methodology is finalized. The process involves assessment, public comment, and potential legal challenges.

Part of Larger Trend: This initiative joins other 2025 FDA actions including the ban on Red Dye No. 3, restrictions on PFAS in food packaging, and approvals for natural color alternatives. The cumulative effect suggests a new era of stricter oversight.

Conclusion

The FDA's Post-Market Assessment Prioritization Tool represents one of the most significant changes to U.S. food chemical regulation in decades. By shifting from reactive case-by-case review to systematic, science-based assessment, the agency may finally address the thousands of chemicals that entered the food supply without modern safety scrutiny.

For consumers weary of navigating ingredient lists filled with unpronounceable additives, the promise is straightforward: a food system where chemicals are systematically evaluated for safety rather than grandfathered in indefinitely. Whether the tool delivers on that promise will depend on its final implementation—and the FDA's willingness to act on the rankings it produces.