In an era where consumer safety, supply chain transparency, and data-driven policy are paramount, the U.S. Food and Drug Administration (FDA) is taking a pivotal step toward modernizing chemical oversight. In July 2025, the FDA extended the comment period for its proposed Chemical Exposure and Risk Ranking Index (CERRI)—a groundbreaking initiative to prioritize chemicals in food through a transparent, risk-based system.
This move signals a significant shift in how chemicals in food are regulated. For third-party labs, especially multidisciplinary ones like CMDC Labs, it opens the door to a crucial supporting role—helping food and beverage manufacturers, packaging firms, and raw material suppliers align with emerging risk classification protocols.
Let’s explore what the new chemical ranking tool is, why it matters, and how testing labs must prepare for the upcoming regulatory shift.
What Is the FDA’s Chemical Ranking Tool?
The CERRI system is designed to help the FDA identify and rank chemicals used in food (including food contact substances and additives) based on two core metrics:
- Level of exposure in the U.S. food supply
- Potential toxicity based on available scientific data
By cross-referencing consumption data, toxicology reports, and chemical use trends, the FDA aims to classify and rank substances to better prioritize regulatory oversight, re-evaluation, or even removal from the market if risks are deemed unacceptable.
The model is still evolving, but its structure integrates:
- Exposure estimates from NHANES dietary data
- Hazard profiles drawn from existing toxicological databases
- Scientific uncertainty scores for data-deficient substances
- Weighting algorithms to prioritize chemicals of concern
The comment period extension (from July 2025) reflects the FDA’s desire to gather more industry feedback before implementation.
Why This Matters to the Food and Packaging Industry
The U.S. food system currently allows thousands of direct and indirect additives—many of which haven’t been re-evaluated in decades. With rising concerns about endocrine disruptors, PFAS, heavy metals, and chemical leaching from packaging, public and political pressure has grown for regulators to modernize risk frameworks.
Here’s what this new ranking system implies for stakeholders:
- Greater regulatory scrutiny of “Generally Recognized as Safe” (GRAS) chemicals
- Re-evaluation of older additives approved under outdated science
- Pressure on manufacturers to reformulate ahead of policy shifts
- Transparency demands from consumers and advocacy groups
And perhaps most critically—independent lab validation will become a key pillar in demonstrating compliance, screening for red-flag chemicals, and preparing robust documentation during regulatory audits.
What It Means for Testing Labs
For labs like CMDC Labs, the FDA’s chemical ranking framework represents not just a regulatory checkpoint—but a strategic opportunity to support clients across multiple industries.
1. Toxicological Risk Screening
As the FDA zeroes in on high-risk or high-exposure chemicals, clients will require:
- Identification of substances on their ingredient or packaging lists flagged by CERRI
- Tiered testing panels for high-priority compounds (e.g., BPA, phthalates, PFAS)
- Toxicological profile reports to assess systemic risks and potential liabilities
CMDC Labs can help manufacturers stay ahead of enforcement actions by proactively screening for chemicals likely to rise in priority rankings.
2. Chemical Prioritization & Reformulation Support
Labs can assist product developers and QA teams in evaluating:
- Safer alternatives for concerning substances
- Exposure simulations using migration modeling (especially for packaging)
- Shelf-life implications of chemical substitutions
By aligning testing strategy with likely FDA priorities, CMDC becomes more than a testing facility—it becomes a compliance advisor and innovation partner.
3. Data Documentation for Regulatory Submissions
The FDA’s new ranking framework is data-driven—meaning suppliers must provide verifiable exposure, safety, and toxicology data when requested.
CMDC Labs’ ability to:
- Generate structured datasets
- Create test validation reports
- Provide trend-based chemical risk insights
…will be critical for supporting clients during FDA queries or GRAS self-determination processes.
Early Action vs. Delayed Response: The Compliance Gap
Businesses that act now—by auditing their chemical exposure risks and testing accordingly—will likely:
– Avoid recalls due to non-compliant additives
– Maintain consumer trust as watchdog groups release exposure maps
– Improve product shelf stability by identifying optimal alternatives
– Reduce risk of litigation tied to chemical overexposure or toxicity
On the flip side, inaction could lead to:
– Delays in approvals for new product launches
– Sudden reformulation pressure from regulators or retailers
– Costly recalls or product relabeling
– Damage to brand equity in the era of consumer-led transparency
How CMDC Labs Can Help Clients Prepare
CMDC Labs is well-positioned to offer cross-functional support as the FDA’s chemical risk ranking system moves closer to operational use.
Our Core Offerings Include:
- Targeted Chemical Testing Panels: Focused on common additives, contaminants, and migration-prone substances.
- Migration Modeling for Food Contact Materials: Evaluating potential exposure from packaging over time.
- Toxicology Advisory Reports: Helping clients understand and reduce compound-specific risks.
- Regulatory Strategy Consulting: Aligning test plans with FDA’s emerging compliance benchmarks.
Practical Steps for Manufacturers & Brands
If you’re operating in food, beverage, packaging, or food-contact sectors, here’s how you can prepare:
Step 1: Audit Your Ingredients & Materials
- Identify substances that may fall under CERRI prioritization (e.g., emulsifiers, colorants, processing aids).
Step 2: Conduct Risk-Based Testing
- Use labs like CMDC to test for exposure levels and establish baseline safety benchmarks.
Step 3: Prepare Documentation
- Retain all lab reports, toxicological data, and test validations for potential FDA inquiries.
Step 4: Explore Safer Alternatives
- Work with formulation experts to find substitutes that reduce consumer and environmental risk.
Looking Ahead: Toward Proactive Chemical Safety
The FDA’s chemical ranking tool isn’t just a bureaucratic step—it’s a signal that chemical safety is becoming central to modern food regulation. The industry is transitioning from a permissive model to a predictive one, where labs and science-led data shape what reaches the shelf.
At CMDC Labs, we understand that today’s compliance landscape is tomorrow’s competitive edge. We’re not just keeping up with change—we’re helping define it.
Final Word
The FDA’s CERRI tool represents a shift toward science-based prioritization of chemical risks in the food supply. For labs and manufacturers alike, this is a pivotal moment to act—not react.
Whether it’s validating your exposure levels, auditing your ingredient profiles, or building a risk resilience strategy—CMDC Labs is here to support your compliance journey, every step of the way.
Verified Sources:
- U.S. FDA: Chemical Exposure and Risk Ranking Index (CERRI)
- U.S. FDA – Federal Register Notice on Comment Period Extension (July 2025)
- U.S. NHANES Dietary Exposure Datasets (CDC)
- Food Chemical News coverage, 2025 updates
