Dietary supplement regulations are sexy again. After a banner year with consumers, investors and cabinet-level officials in the Trump Administration, supplements are poised to take a significant role in the unfolding of the Make America Healthy Again (MAHA) agenda now governing public health in this country.
All of a sudden, everybody wants to parse the regulatory tea leaves, so it’s important to identify the right tea leaves for parsing. SupplySide Supplement Journal queried the industry’s leading trade associations to highlight their top priorities for 2026, and it’s interesting to see how their choices dovetail with and depart from the priorities issued Jan. 23 by the Food and Drug Administration’s (FDA) Human Foods Program.
FDA called out GRAS (generally recognized as safe), new dietary ingredients (NDIs), “oversight modernization” and caffeine labeling as items of focus in 2026.
Here’s what the trades called out.
UNPA: ‘The whole highway is under construction’
At the United Natural Products Alliance (UNPA), 2026 is a year in which every major path to market for supplements is up for debate.
“The whole highway is under construction,” says Loren Israelsen, founder and president. “All three lanes are in play — GRAS affirmation, NDIs and even ODIs (old dietary ingredients). Some lanes might close down, but others will open up or expand.”
Reforms to the self-affirmed GRAS process will likely raise the bar a bit on safety dossiers, but also raise many questions about who has the regulatory staff to handle any increase in reviews and how long it will take to hear back.
“Companies might agree to shift over from GRAS without notice to now file with notice, but pray tell, who at FDA can handle this?” Israelsen said. “It’s a fair question — are you staffed for this after being destaffed last year?”
With NDIs, the promise of new news from FDA with a deadline last October was clearly impacted by the government shutdown, so the industry remains in draft mode. Israelsen is thinking through the calculations that companies might soon be forced to make between GRAS or NDI and the intended use of a product. If an ambitious supplement company wants to play across the categories of food and nutrition, will it need both GRAS notification and an NDI?
The wildcard here is a meaningful update to the old dietary ingredient grandfathered list, a call to arms that Israelsen has been sounding for some time.
“We have to better understand the context of a ‘lookback approach’ and improve ODI 1.0,” he said. “Entire categories of ingredients are missing, and others have seen updates to their nomenclature. FDA uses this list often, and they always say ‘let’s keep talking’ about ODI 2.0.”
Done right, these updates to market entry could land as an upgrade, according to Israelsen. Everyone’s understanding of the rules gets a refresh, gaps are filled, rigor is added, and consumers gain more confidence in the safety and benefit of the category.
“If we do this right, it’s not just more regulatory work to be done,” he says. “It’s a strong net-plus.”
CRN: Oppose state bills restricting access
Top of the list at the Council for Responsible Nutrition (CRN) is protecting consumer access to supplements, primarily through the organization’s opposition to restrictive bills at the state level and promotion of supplements for FSA/HSA eligibility at the federal level.
“At the state level, we are redoubling our efforts to defeat legislation that would impose age restrictions on broad classes of weight management and sports nutrition products,” President and CEO Steve Mister said. A CRN lawsuit remains active in New York, and the organization is working to build out a “coalition of stakeholders” in additional states.
To expand innovation within the industry and promote consumer trust, CRN is paying close attention to that “oversight modernization” mentioned by FDA in its release. Under this bucket, CRN would highlight the need for balance in the drug preclusion process (more on that below), federal preemption for the entire industry to “prevent a hodgepodge of inconsistent state laws” and allowing FDA to use third-party audits to inform inspection priorities.
The return of Sen. Dick Durbin’s legislation calling for the premarket registry of supplements also makes the list.
“A mandatory registry, far from giving FDA premarket approval or undermining DSHEA, will give FDA tools to strengthen oversight, target bad actors, and build consumer trust — while supporting responsible industry growth through science-based, nationally consistent policy,” Mister said. “Not coincidentally, these goals also align with MAHA’s objective of empowering consumers with better choices to promote their own health.”
CHPA: Support practical reforms to GRAS
“We’re closely watching proposed changes to the GRAS framework,” said Duffy MacKay, ND, SVP of Dietary Supplements at the Consumer Healthcare Products Association (CHPA). “Greater transparency and consumer confidence are important goals, but reforms need to be practical, science-based and designed in a way that strengthens FDA oversight without overwhelming the agency or creating unintended consequences for dietary supplements.” His organization is actively engaged with FDA, OMB and policymakers on this front.
CHPA is taking a broad lens to the regulatory activity happening at the state level. Driven by perceived gaps in federal oversight, these efforts may unintentionally impact dietary supplements, even when supplements weren’t the original target.
“Our work is centered on educating lawmakers about FDA’s existing authority, advocating for consistent national standards, and helping ensure policies enhance safety without fragmenting the regulatory landscape,” MacKay said.
AHPA: Fight for more trade exemptions and a pathway for hemp
“AHPA is committed to working with FDA to ensure that any GRAS reform avoids unintended market disruptions, and that a timely, fully resourced review process is established,” says Graham Rigby, president and CEO at the American Herbal Products Association (AHPA).
The goal is to protect continued access to safe botanicals and dietary ingredients if there’s a fundamental shift away from the self-affirmed pathway.
With a global supply chain challenged by the volatility in tariffs and geopolitics, AHPA continues to fight for additional trade exemptions.
“We are meeting directly with Congress, the U.S. Trade Representative, the U.S. Department of Commerce and foreign embassies to advocate for targeted relief,” he said, “specifically for botanical resources that cannot be grown domestically at commercial scale.”
Exemptions for many imported herbs have been successfully secured, with AHPA now advocating for similar relief for herbal extracts and specialized manufacturing equipment.
Federal hemp legislation has shifted in recent months from a permissive stance to stricter definitions that threaten to reclassify products out of compliance.
“Establishing a clear, science-based federal regulatory pathway for hemp-derived products remains a critical focus to ensure the viability of the hemp and CBD markets,” Rigby said.
AHPA is working with lawmakers to replace the current patchwork of restrictions with a robust framework that prioritizes transparency, botanical integrity, and consumer safety.
NPA: Fix the ‘drug preclusion’ clause
At the Natural Products Association (NPA), the focus lands on those state laws attempting to limit access to weight loss and muscle-building supplements, as well as a more permanent fix to the “drug preclusion” clause of DSHEA.
Under this clause, FDA has disallowed certain ingredients in supplements because of their prior role in an investigational new drug application (IND).
“NPA has successfully challenged FDA determinations that NAC (N-acetyl-L-cysteine) and NMN (nicotinamide mononucleotide) are precluded in supplements, but that work in the executive and judicial branches of government was capital — and resource — intensive,” said Josh Long, vice president of communications and regulatory affairs. “Simply put, supplement brands and ingredient suppliers need a permanent legislative fix, or change, to the drug preclusion clause in DSHEA.”
At the state level, NPA is focusing on legislation in Congress that would expressly preempt state laws that conflict with and undermine DSHEA, including the statute’s demonstrable intent to support access to safe supplements. Accordingly, NPA will continue to deploy its staff and lobbyists to statehouses in 2026, and organize Fly-In Days on Capitol Hill so that legislators and their aides can hear directly from industry leaders.
