Does the deadline apply to imported food too?

Yes. FDA explicitly says foods imported to the U.S. must comply with U.S. requirements.

Is Red No. 3 the same as the broader 2027 dye phaseout discussion?

No. Red No. 3 has a revoked authorization and a fixed compliance deadline for food. FDA's broader certified-color page tracks company and association commitments on other dyes, but those commitments are not the same thing as Red No. 3's revocation order.

Red No. 3 Deadline: What Food Importers Must Do Before Jan 2027

FDA revoked the authorization for FD&C Red No. 3 in food on January 15, 2025, and manufacturers using it in food have until January 15, 2027 to reformulate. FDA has also been explicit that foods imported into the United States must comply with U.S. requirements, even if the exporting country still allows the color additive. For importers, that makes Red No. 3 a supplier-management problem now, not a labeling problem in late 2026.

FDA then turned up the pressure in July 2025 by encouraging manufacturers to accelerate phaseout before the 2027 deadline. Separately, FDA is now publicly tracking industry pledges to remove other certified color additives on timelines that often run through the end of 2027. The key distinction is important: Red No. 3 has a revoked authorization and a hard food deadline; many broader dye changes are still a mix of agency pressure and industry commitments, not the same legal posture.

What importers should do now

The practical question is not "does my supplier know about Red No. 3?" The real question is: which SKUs still contain it, when does each supplier's compliant reformulation go live, and when do old labels stop shipping to the U.S.?

For most importers, the work falls into four stages.

Stage 1: Ingredient mapping

Map every U.S.-bound SKU that could contain FD&C Red No. 3, erythrosine, or a supplier-specific equivalent naming convention. Do this at the formulation level, not just the master brand level. One private-label line can hide multiple formulas across countries or plants. The reason to start here is simple: imported foods do not get extra time.

Stage 2: Supplier commitment

Get written confirmation from every supplier on three things: the reformulated ingredient deck, the first compliant production date, and the last noncompliant shipment date for U.S. commerce. FDA has publicly encouraged companies to finish earlier than the statutory deadline, so importers should not build their internal timeline around the very last day if they can avoid it.

Stage 3: Label conversion

Once the formula changes, the label has to change with it. That means revised ingredient statements, revised proofs, and a controlled plan for depleting old packaging so noncompliant inventory is not still moving toward U.S. entry in late 2026. FDA's food labeling framework applies to imported food as well as domestic food.

Stage 4: Entry-date discipline

By Q4 2026, your customs and regulatory teams should be treating any U.S.-bound shipment containing Red No. 3 as a live escalation item. The risk is not just "bad optics." The risk is that a U.S.-bound product arrives after the deadline with a formula that can no longer lawfully be used in food.

Red No. 3 Deadline: What Food Importers Need to Do Before January 15, 2027