For more than 80 years, Standards of Identity (SOIs) have served as one of the most important guardrails in the U.S. food and beverage industry. Born in 1939 under the Federal Food, Drug, and Cosmetic Act, these definitions were designed to protect both businesses and consumers from fraud, misrepresentation, and inconsistent product quality. They set legally binding criteria for what a food product must contain—and how it must be labeled—to be sold under a given name.

The stakes for manufacturers could not be higher. An SOI doesn’t just define your product; it determines whether your labeling is legal, whether you can sell in certain markets, and whether your brand is perceived as authentic and trustworthy. A single shift in an SOI can ripple through your sourcing, production, packaging, and marketing strategies.

Today, that stability is being challenged. With over 250 SOIs on the books, the FDA is actively reviewing, revising, and—in some cases—revoking them entirely. On July 16, 2025, the agency announced a final rule to remove 11 SOIs for products no longer commonly marketed and the proposed revocation of 41 more. The catalyst came during the Trump Administration’s push to modernize what it deemed “unnecessary and obsolete” definitions. Some of the affected standards are obscure foods (Nuworld cheese?) but others are more common in the marketplace, such as frozen concentrate for colored lemondade.

Some manufacturers may not even realize their product is bound by an SOI, let alone that the definition is changing. Even if your category isn’t under review today, these changes are a stark reminder: you must know whether your products fall under an SOI—and whether you are in compliance—before the market forces that definition to evolve without your input.

The Latest Action — How and Why the FDA Is Modernizing SOIs

The most recent example—and a revealing case study—is the FDA’s proposal to revise the 60-year-old SOI for pasteurized orange juice, reducing the minimum required Brix (a measure of sugar content) from 10.5% to 10%.

This change is driven by more than just consumer preference. FDA’s action was prompted by a petition from the Florida Citrus Processors Association and Florida Citrus Mutual. Climate change, citrus greening disease, and broader agricultural pressures have made it increasingly difficult for growers to consistently meet the higher threshold. Without a revision to the standard, producers risk higher costs, lower yields, and, in some cases, the inability to bring a product to market at all.

This single adjustment may seem minor, but it signals something bigger. If climate and agricultural realities can trigger revisions here, similar changes could be in store for other product categories—canned fruits, dairy, breads, frozen desserts, and more.

What industry must understand is that this is not an isolated event. It is part of a broader modernization effort, where definitions created decades ago are being re-examined in light of today’s supply chains, production technologies, and global trade realities.

Why This Matters Beyond Orange Juice

While the orange juice change dominates headlines, the true impact of SOI modernization will be felt across many categories. The implications are both promising and risky—depending on how your organization responds.

Pros of Modernizing SOIs

Greater flexibility in sourcing and formulation can lower costs and expand supplier options. Manufacturers may have more room to innovate, experimenting with new blends or alternative ingredients that were previously excluded by rigid definitions. For example, the standard of identity for “artificially sweetened canned pears” limited the sweetener to saccharin or sodium saccharin. Revocation of this standard allows for the introduction of alternate sweetener ingredients. This could open entirely new product lines, allowing brands to capture emerging market trends faster.

Cons and Risks

Relaxed standards also carry the risk of consumer perception shifting toward “lower quality.” Even if taste and nutritional differences are minimal, public perception is often shaped by headlines and marketing spin, not the fine print of regulation. Reformulation can introduce technical hurdles, require rebranding, and, in some cases, alienate loyal customers who view the old definition as synonymous with authenticity. If standards loosen too much, market confusion can erode trust industry-wide.

Business Impact

Operationally, manufacturers must prepare for labeling changes, compliance checks, and potential packaging redesigns. Strategically, shifts in the competitive landscape may create both vulnerabilities and opportunities—those who move early to adapt could secure a long-term advantage over slower competitors.

Potential Industry Missteps and Pitfalls

As definitions change, so does the risk profile for businesses. The most damaging mistakes often stem from underestimating the ripple effect of a single revision.

For example, a change in one product’s SOI could trigger reformulation or labeling updates across multiple SKUs, especially in product lines with shared ingredients. Another trap is assuming that minimal change to taste or nutrient content will mean no consumer pushback—brand trust is fragile, and perception can shift overnight.

Internationally, some export markets or retailers may continue to enforce the older standards, creating a dual compliance challenge. And perhaps the most avoidable misstep is compliance lag—waiting too long to act, which can lead to regulatory citations, product recalls, or costly delays in bringing reformulated products to market.

Strategic Steps Companies Can Act On Now

If your category is affected—or could be soon—there are proactive moves that can protect your compliance and competitive standing.

First, conduct an SOI audit to identify all products tied to a standard currently under review. Engage in the public comment process to influence how the final rule is shaped. Run consumer testing on potential reformulations to gauge market reaction before changes are implemented.

Prepare regulatory, labeling, and marketing teams to operate in sync, ensuring packaging, compliance, and communications are aligned for simultaneous rollouts. Finally, scenario-plan for related shifts in your category so you aren’t starting from zero if another SOI changes unexpectedly.

Looking Ahead — SOIs as a Competitive Lever

SOIs are not disappearing. They remain a foundational element of U.S. food regulation. But the role they play is changing. Where once they were viewed primarily as compliance hurdles, they can now serve as strategic levers for innovation and market differentiation.

The companies that will thrive in this environment are those building internal agility today—creating processes and teams that can respond quickly to regulatory changes without sacrificing quality or brand trust.

The modernization of SOIs is not just a regulatory update; it’s a shift in the rules of competition. Those who embrace the opportunity will shape their categories. Those who delay may find the market reshaped without them.