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The Food System Was Built Before Many of Us Had a Seat at the Table. Now We Have a Chance to Change It.
- IamWANDA org
- Aug 13
- 12 min read
The Trump administration’s proposed overhaul of the GRAS system offers a rare opportunity to reconsider not only what is allowed in American food, but who gets to decide—and what it means to participate in the food system as a citizen rather than simply a consumer.
By Tambra Raye Stevenson
When an invitation arrived for me to attend an August 10th food policy announcement at the U.S. Department of Health and Human Services, I was curious about what, exactly, we were being invited to celebrate.
The announcement concerned a regulatory acronym most Americans have probably never discussed around their dinner tables: GRAS, or “Generally Recognized as Safe.” HHS and the Food and Drug Administration announced a proposed rule that would require manufacturers to notify FDA when they determine that an ingredient qualifies as GRAS. The administration also announced that a proposed federal definition of “ultra-processed food” has moved forward for additional White House review. Both developments could prove consequential. Neither is as simple as removing a list of “bad ingredients” from the American diet.
To understand why, it helps to return to the America in which GRAS was born. In 1958, the United States was becoming a different kind of eating nation. The postwar kitchen was filling with technologies that promised freedom from older forms of food labor. By the early 1950s, refrigerators had become common in American homes. Freezer compartments expanded. Frozen vegetables, concentrated juices, prepared meals, canned foods, cake mixes, and other convenience products promised to make feeding a family faster and easier.
The Smithsonian’s National Museum of American History describes this period as one in which postwar technologies, changing work patterns, suburbanization, supermarkets, television, and mass manufacturing reshaped both American cooking and American expectations of food. The famous television dinner appeared in 1953. The package, the freezer, the supermarket aisle, and eventually the television commercial became increasingly important actors at the family table.
Convenience should not be romanticized as some kind of nutritional original sin. For women in particular, reducing kitchen labor could represent genuine freedom. Black women have perhaps more reason than most to resist nostalgia for an imagined era when everyone supposedly cooked wholesome meals from scratch. Black women have long performed paid labor outside their homes while carrying disproportionate responsibility for feeding children, caring for relatives, and, historically, cooking and cleaning in other people’s homes as well.
A refrigerator could be liberation. A freezer could be liberation. Canned beans on a Wednesday night can still be liberation.
The more important question is what happened as technology, manufacturing, and chemistry began transforming food faster than the public’s ability to understand or govern those changes. That was the context in which Congress passed the Food Additives Amendment of 1958 and created what became known as the GRAS exemption.
The original logic was reasonable. Congress did not intend to require elaborate regulatory review every time manufacturers used ingredients with long histories of safe use, such as common seasonings and familiar food substances. Under the law, certain substances could be exempted from the definition of a food additive when their safety was “generally recognized” by qualified experts under their intended conditions of use.
But the year matters.
This was 1958. Six years before passage of the Civil Rights Act and seven years before the Voting Rights Act. The regulatory architecture that helped shape today’s industrial food system was created in an America where Black citizens still confronted legally sanctioned segregation and widespread voter suppression, and where Black women had extraordinarily little representation inside the institutions making decisions about agriculture, science, commerce, health, and regulation.
That does not mean the original GRAS framework was designed as a racial policy. It does mean we should resist the fiction that regulatory systems emerge outside history.
Rules inherit the assumptions, institutions, technologies, and power relationships of the societies that create them. When those rules remain in place for generations while the marketplace around them changes dramatically, periodically asking whether the structure still serves the public becomes part of democracy.
A Food Supply the Authors of GRAS Could Hardly Have Imagined
The first FDA GRAS list included roughly 200 substances. Today, the scale and complexity of the U.S. food supply are almost unrecognizable by comparison. Associated Press has reported estimates of approximately 10,000 substances used as additives or in food-related applications in the United States, encompassing everything from preservatives and emulsifiers to colors, flavoring agents, and substances associated with packaging.
There is remarkable science in that accomplishment. There is also a legitimate public-health question.
Under the current GRAS framework, manufacturers may determine that the intended use of a substance qualifies as generally recognized as safe. The public often assumes that anything appearing in packaged food must have been individually tested and approved by FDA before reaching the market. That is not necessarily how the system works.
Historically, companies have not always been required to notify FDA when making their own GRAS determinations.
This is why the administration’s proposal matters. Under the proposed reform, manufacturers would be required to tell FDA about GRAS conclusions, and the agency says it intends to develop a more transparent public inventory of those notices.
That represents an important shift toward visibility.
It should not, however, be mistaken for universal government premarket approval. Requiring companies to report a determination is different from requiring FDA to independently conduct a full safety review before every substance reaches the market. FDA officials have acknowledged that broader mandatory review authority would require congressional action.
That distinction is particularly important as conversations about ultra-processed foods migrate from scientific journals into social media feeds.
The United States is now developing its first federal definition of ultra-processed food. HHS estimates that nearly 60 percent of calories in the American diet come from ultra-processed foods. But the definition itself remains unsettled, and the category can be deceptively complicated.
Processing is not inherently harmful. Humans have transformed food for thousands of years. We ferment it, grind it, smoke it, dry it, pound it, pickle it, freeze it, and preserve it. Bread is processed. Yogurt is processed. Canned beans and frozen vegetables are processed. Processing can improve food safety, reduce waste, preserve nutrients, make foods more affordable, and help disabled people, older adults, students, caregivers, and working parents put meals on the table.
The challenge is not deciding whether a machine touched our dinner. It is understanding what type of processing occurred, why it occurred, what was added or removed, what evidence supports the safety of those substances, how heavily those products dominate the diet, how they are marketed, and what foods they displace. Those are more complicated questions than an Instagram pantry clean-out.
From Hunger to Hyper-Processing
The history of U.S. nutrition policy helps explain why the country has arrived at this moment.
Eleven years after passage of the Food Additives Amendment, the Nixon administration convened the 1969 White House Conference on Food, Nutrition, and Health. The United States faced an uncomfortable contradiction: It was one of the richest and most agriculturally productive nations in the world, yet hunger and malnutrition persisted.
The conference helped accelerate an extraordinary period of federal nutrition policymaking. Food assistance expanded. School meals grew. The School Breakfast Program became permanent. The groundwork was laid for the program that eventually became WIC.
That generation confronted a fundamental moral question: How could a wealthy nation tolerate hunger?
By 1980, federal policy had moved toward another question: What should Americans eat? The first Dietary Guidelines for Americans institutionalized national dietary advice. The Nutrition Labeling and Education Act of 1990 added another layer. Standardized nutrition information allowed consumers to turn packages around and see calories, sodium, fat, fiber, and other nutrients.
That was an important democratization of information. But something else happened along the way. The responsibility for navigating an increasingly complicated industrial food system settled heavily on the individual eater.
Read the label.
Watch the sodium.
Count the calories.
Limit the fat.
Choose better.
Exercise more.
Nutrition education became extraordinarily good at telling people how to navigate the marketplace without always asking whether the marketplace itself required intervention.
The 2022 White House Conference on Hunger, Nutrition, and Health began moving the national conversation toward the relationship between hunger, diet-related disease, inequity, and the broader food environment. The present debate over GRAS and ultra-processed foods takes the next step: It turns attention upstream toward the composition of the food supply itself.
The public-health question has therefore evolved over nearly seven decades. In the late 1950s, policymakers were asking whether particular substances could safely enter a rapidly modernizing food supply. In 1969, the country confronted hunger. By the 1980s and 1990s, government emphasized dietary guidance and consumer information. Today, Americans must ask whether individual choice can realistically shoulder the burden created by an extraordinarily sophisticated food environment.
Black Women Already Carry Enough of That Burden
That question matters particularly for Black women because American nutrition discourse has an unfortunate habit of locating structural problems inside individual bodies.
Black women are routinely told to lower our blood pressure, lose weight, prevent diabetes, breastfeed, exercise, cook more, consume less sodium, eat more vegetables, and feed our children differently.
Some of that advice is medically sound. But advice without context can become accusation.
USDA reported that 13.7 percent of American households experienced food insecurity in 2024. The rate of very low food security was 5.4 percent nationally, but 10.5 percent among Black households and 12.9 percent among households with children headed by a single woman. Among Black households with children, nearly one-third experienced food insecurity.
Meanwhile, CDC reported a 2024 maternal mortality rate of 44.8 deaths per 100,000 live births among Black women compared with 14.2 among White women. Diet alone does not explain Black maternal mortality, and suggesting otherwise would be both scientifically irresponsible and historically tone-deaf. Racism within healthcare, quality of care, chronic stress, environmental conditions, insurance, income, and many other factors shape those disparities.
But food is part of the environment in which health happens. A woman can simultaneously be told to eat a healthier diet and live in a neighborhood where nutritious food is harder to obtain. She can receive counseling about sodium while working jobs that leave little time for cooking. She can be told to avoid certain packaged foods while using SNAP and trying to stretch benefits through the end of the month.
She can be urged to “read the label” while having no meaningful way to know who determined that an unfamiliar ingredient on that label was safe. The problem is not that she lacks discipline. She is navigating policy.
If the national response to ultra-processed foods becomes another campaign telling low-income mothers what they should stop buying, we will have missed the point entirely.
The goal cannot be to replace “Why are you overweight?” with “Why did you buy that packaged food?”
We should instead ask why certain products dominate certain neighborhoods, why healthier alternatives may cost more, how foods are marketed to children, how public benefits shape purchasing options, what hospitals and schools serve, and how much regulatory responsibility should rest with companies rather than consumers.
Europe Regulates the Question Differently
Comparisons between the United States and Europe often descend into slogans about ingredients being “banned in Europe.” The reality is considerably more complicated.
European diets contain processed foods. European countries contend with obesity and diet-related disease. An ingredient permitted in one jurisdiction and restricted in another is not automatically proof that one population is being poisoned.
The regulatory philosophies, however, are meaningfully different. In the European Union, food additives generally must undergo safety assessment and receive authorization before they can appear on the list of permitted additives. The European Food Safety Authority evaluates evidence related to toxicology, exposure, manufacturing, and intended use, and authorized substances can be reevaluated when new scientific information emerges.
The U.S. GRAS system has historically provided greater space for manufacturers to establish safety recognition without requiring the same kind of mandatory FDA premarket authorization for every use falling under the exemption. The more useful comparison is therefore not “Europe good, America bad.” It is a question of where societies place the burden of proof. How much responsibility should industry carry before introducing a substance into the food supply? How much should government verify? How much uncertainty should the public be asked to accept? Those are not simply scientific questions. They are political questions about the distribution of risk and responsibility.
The African Diaspora Offers a Different Way of Seeing Food
There is another comparison worth making one that too often disappears from American nutrition conversations. Brazil has become internationally influential for dietary guidelines that look beyond individual nutrients and consider the nature and purpose of food processing. Its guidance emphasizes fresh and minimally processed foods, home and communal meals, cooking, and protection from aggressive food marketing. The approach recognizes something that Black food traditions have long understood: A meal is more than its chemical composition.
Across the African continent, countries are confronting a difficult nutrition transition: undernutrition persists in many places even as obesity, hypertension, diabetes, and other chronic diseases rise. Urbanization and economic change have reshaped food environments, and inexpensive highly processed foods increasingly coexist with longstanding traditional foodways.
South Africa, for example, has gone beyond nutrition education and used fiscal policy through its Health Promotion Levy on sugar-sweetened beverages. These approaches are imperfect, and the African continent is far too diverse to treat as a single food-policy system. But together, Brazil, African nations, and other parts of the diaspora raise a question U.S. nutrition policy has historically struggled to ask: What happens when industrial food changes not merely what people consume but what they recognize as food?
A child can become more familiar with a corporate cereal mascot than millet. A parent can come to regard an ancestral grain as inconvenient while a brightly packaged snack feels normal. Foods eaten for generations can become “ethnic,” while industrial products manufactured only decades ago become culturally invisible. That is not merely nutritional change. It is narrative change. It affects belonging.
What My Grandmother Knew That the Package Cannot Tell Me
When my grandmother taught me something about food, I knew the source. I could ask where the recipe came from. I could ask who taught her. I could learn why an ingredient was used, what happened when somebody was sick, what people cooked when money was scarce, and what food appeared when the family gathered. Her knowledge had provenance.
Modern nutrition gives us extraordinary quantities of information, but provenance is often harder to see.
A package may tell me how much protein it contains, but not why a particular formulation became normal. It may list an additive without telling me who determined that its intended use was safe. It can tell me the serving size while saying nothing about the advertising system that convinced my child she needed the product. This is where the discussion of GRAS becomes larger than GRAS. The question is no longer merely whether individuals understand nutrition. It is whether people understand the systems governing their nourishment. For decades, we have been teaching Americans to become increasingly sophisticated food consumers. Perhaps what this moment requires is something different.
The Swap We Need to Make
We live in a culture fascinated with food. We follow chefs. Photograph our meals. Travel for restaurants. Debate barbecue. Argue about who makes the proper jollof. Buy cookbooks we may or may not cook from. We have become a nation of foodies. There is nothing wrong with that. Food deserves pleasure. Beauty matters. Flavor matters. Celebration matters. But being a foodie is primarily a relationship to food through consumption.
A foodie asks where to eat.
A food citizen asks who gets to eat.
A foodie knows the chef.
A food citizen wants to know the farmer, the worker, the regulator, the manufacturer, and the policymaker.
A foodie reads the menu.
A food citizen reads the law.
A foodie asks what is in the dish.
A food citizen asks who decided the ingredient could be there.
A foodie discovers the newest food trend.
A food citizen asks what happened to the food traditions that trend displaced.
A foodie votes with her fork.
A food citizen understands that sometimes she needs to vote with an actual vote, a public comment, a testimony, a petition, a purchasing decision, a community garden, a school-board question, or a demand that government act. That is the swap I want us to make.
From foodie to food citizen. Not because we should stop loving food. Because loving food should make us curious about the systems responsible for feeding us. This fall, as FDA moves through its GRAS rulemaking process and the federal government continues developing its definition of ultra-processed food, families should not wait for scientists, lobbyists, manufacturers, and regulators to have the entire conversation among themselves.
Black women should be part of it. Mothers should be part of it. Farmers, dietitians, doulas, teachers, community health workers, small food businesses, faith communities, SNAP and WIC participants, people managing diabetes and hypertension, parents whose children eat school meals, and the communities bearing disproportionate burdens of diet-related disease should all be part of it.
We should ask whether FDA has sufficient authority and resources to independently investigate safety concerns. We should insist that whatever public GRAS database emerges is usable by ordinary citizens rather than merely technically public. We should ask how conflicts of interest are managed and how old safety determinations are revisited as science changes. And as the nation defines ultra-processed food, we should demand a framework sophisticated enough to distinguish an industrial formulation from a can of beans, a loaf of useful bread, a frozen vegetable, or a culturally meaningful food preserved using methods people have relied upon for generations.
Most of all, we should reject the idea that the ultimate purpose of food policy is producing increasingly perfect shoppers. The American food system of 2026 would be unimaginable to the lawmakers who created GRAS in 1958. Our democratic expectations should have evolved just as much. We should know what is in our food. But we should also know who decided it could be there. We should learn how to read the label. But we should also learn how to read the policy. We should teach our children to make nourishing choices. But we should also teach them that they have the right to question the environment in which those choices are made. The most important food swap we make this year may have nothing to do with replacing one ingredient with another.
Swap the identity of the foodie for the power of the food citizen. Keep the pleasure. Keep the recipes. Keep the restaurant reservations, the family reunions, the Sunday dinners, the jollof arguments, the gardens, the cookouts, and the joy. But add citizenship.
Ask questions.
Follow the policy.
Protect the memory.
Challenge the marketing.
Demand transparency.
Show up where the rules are written.
Because the next generation will inherit more than our recipes. They will inherit the food system we were willing or unwilling to change.
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