Few product teams in food and beverage are standing still.
Clean-label expectations, shifting regulatory requirements, volatile ingredient supply and relentless cost pressure have turned reformulation into a continuous activity rather than an occasional project. Many manufacturers now have dozens of recipe changes moving through their pipeline at any given moment.
Every one of those changes ripples outward. A new ingredient or an alternate supplier alters the specification – and that can change the allergen profile, the nutrition declaration, the on-pack claims and the artwork that reaches the shelf. The reformulation itself is rarely the hard part. Keeping everything that depends on it accurate and in sync is.
When a formula changes and the label doesn’t
When a recipe changes and that change doesn’t reach every downstream document, the result is a label that no longer matches what’s in the pack. In the EU, that can mean a nutrition declaration that no longer adds up, an allergen missing from the list – Regulation (EU) No. 1169/2011 requires 14 named allergens to be declared and emphasised in the ingredients – or a nutrition or health claim the new recipe no longer supports under Regulation (EC) No. 1924/2006.
The consequences scale fast: relabeling and holds, retailer delisting, product withdrawals, or in the worst case a recall and regulatory action. And the rulebook is only getting denser. For manufacturers who also export to the US, the same formula change then has to satisfy an entirely different framework: the FDA’s labelling rules and a federal allergen list of nine – often with different thresholds and different wording on the pack.
Why it breaks: The data lives in too many places
Failure is rarely a lack of expertise. It’s that product data is scattered. The formula sits with R&D, the allergen and claims logic sits with regulatory, the supplier documentation sits with procurement, and the label artwork sits with packaging or an outside agency – often across spreadsheets, PDFs and systems that don’t talk to each other.
In that setup, a single ingredient change depends on someone remembering to update all of the others, correctly, under deadline. As the pace of reformulation rises, that manual reconciliation is exactly where errors slip in. It isn’t that teams don’t know the rules; it’s that no one has a complete, current view of everything a change touches.
What “good” looks like
The manufacturers who reformulate quickly and safely tend to share one trait: a single, connected source of truth for product data. When the formula is the master record and every specification, claim and label draws from it, a change propagates automatically instead of being re-keyed in five places.
That is the principle behind a modern product lifecycle management (PLM) platform – connecting formulation, specifications, claims and label content so that when an ingredient changes, the system surfaces every spec, claim and label affected, including the supplier documentation those values trace back to.
And because every change is versioned, brands can retain the audit trail that regulatory compliance increasingly demands across the EU and export markets.
A checklist before your next reformulation
A practical way to pressure-test your own process. Before you approve your next recipe change, can you answer “yes” to each of these?
- Single source of truth: Is there one master record for each formula that every spec, claim and label draws from, rather than parallel copies in different tools?
- Automatic impact flagging: When an ingredient changes, does something automatically show you which allergens, nutrition values, claims and labels are affected?
- Supplier data at source: Do your specifications pull directly from supplier documentation, instead of being typed in by hand?
- Claims tied to evidence: Is every on-pack claim linked to the data or certification that substantiates it, so a formula change flags a claim that’s no longer supported?
- Market-specific labels: Can the same product carry correct labelling for the EU and any export markets without being rebuilt each time?
- Audit trail: Could you show a regulator or retailer exactly what changed, when, and who approved it?
Any “no” on that list is a place where a fast reformulation can quietly become a compliance gap.
The takeaway
Reformulation isn’t slowing down, and the compliance landscape isn’t getting simpler. The manufacturers who treat product data as connected infrastructure – not a stack of documents to reconcile after the fact – are the ones who will keep changing their products as fast as the market demands without letting their labels fall out of step.
In a market where a single mismatched label can trigger a recall, keeping specs, claims and labels in sync isn’t administrative housekeeping. It’s how you protect speed and trust at the same time.
Author: Erika Redaelli, global head – solution management, regulatory and scientific at Trace One
Erika Redaelli leads the regulatory and product teams at Trace One, whose AI-native PLM platform is built for formula-based product development in food and beverage and consumer goods, serving both manufacturers and retailers.