As part of Nutraceuticals World’s 2026 State of the Industry review, Duffy MacKay, Senior Vice President of Dietary Supplements, Consumer Healthcare Products Association (CHPA), shares insights on how ingredient safety is shifting from a regulatory requirement to a market-driven standard, as transparency, documentation, and risk management become defining factors.

Representing companies across the OTC medicine, device, and dietary supplement marketplace, we’re seeing a major inflection point, but it’s not just happening in state legislatures. The bigger shift over the last 12 months is that the commercial marketplace is now moving faster than government when it comes to safety expectations and demand for ingredient transparency. 

What was once a technical FDA concept, the GRAS framework, has suddenly become a market signal at the center of broader policy debates. GRAS is moving out of the purely technical FDA domain and into political and industry conversations over who defines safety: states or the federal government, and that tension is now shaping not just regulations, but the future of market access and consumer trust. This is why we’ve seen a wave of state-level proposals attempting to regulate ingredient safety, raising the risk of a fragmented set of regulations replacing a unified federal national standard.

This introduces other new concerns too, as insurers are beginning to factor ingredient safety documentation into underwriting, and global suppliers are asking whether U.S. self-GRAS will converge more closely with Europe’s Novel Foods framework to streamline global market access.

The future of ingredient safety determinations is increasingly being made not only in regulation, but in the commercial terms that govern risk, access, and trust. Heading into 2026, it will be worth watching whether companies that invest in documentation, transparency, and regulatory alignment beyond the federal baseline see advantages in distribution decisions, insurance conversations, and global market confidence, driven by market expectations.

Safety is no longer only a regulatory standard, it’s becoming a commercial standard that determines who moves fastest, and who wins. As this evolves, federal standards must remain the foundation, but the market, and politics, may increasingly define what exceeding that foundation looks like.