Regulatory Changes in Food and Beverage: How to Reformulate Without Losing Consumers

In recent years, different markets have introduced restrictions that directly affect ingredients and solutions used across the industry. In Mexico, erythrosine, also known as Red 3 or E-127, is no longer permitted for the affected applications under the new regulation, giving companies 24 months to reformulate and use up existing stock.

In the European Union, eight authorisations for smoke flavouring primary products have not been renewed, with transitional periods allowing affected product categories to be adapted through 2029.

For R&D, Quality, and Regulatory teams, these changes create a challenge that goes beyond compliance: finding an alternative that works technically while preserving the experience consumers associate with the product.

Regulatory changes are becoming the new normal in food and beverage

Food regulation is continuously evolving. Ingredients, additives, and technological solutions may be subject to new assessments, restrictions, or changes to their permitted conditions of use.

When this happens, product teams have to revisit formulations that may have been working successfully for years.

The first question is usually technical: which alternative can replace the affected ingredient?

The next question should involve the consumer: what impact will that change have on the way the product is perceived?

The Red 3 case in Mexico: 24 months to reformulate

The case of erythrosine clearly illustrates what it means to replace an additive that has become part of an established formulation.

The agreement published in Mexico's Official Gazette introduces new restrictions on the use of erythrosine and establishes a 24-month period for affected manufacturers to reformulate their products and use up existing stocks.

For R&D teams, the first step is to identify a technically viable replacement. However, colour plays an important role in the consumer experience. It influences appearance, shapes expectations, and contributes to product recognition.

A product reformulation involving a colour additive can affect, for example:

• Colour and appearance
• Expectations around flavour
• Perceived intensity
• Visual recognition of the product
• Overall liking

Comparing the current formulation with different alternatives therefore helps determine which replacement best preserves the experience consumers already associate with the product.

The EU does not renew smoke flavouring primary products: the smoky character remains, but the solution changes

The case of smoke flavouring primary products presents a different scenario. The European Commission decided not to renew the authorisations of eight smoke flavouring primary products. The SFPP Regulation establishes transitional periods to facilitate the adaptation of affected products.

This case includes a particularly important consideration for sensory reformulation. The brand may retain exactly the same technological objective: achieving a specific smoky character. What changes is the solution used to achieve it. An alternative may affect:

• Aroma intensity
• Aromatic notes
• Persistence
• Balance with other ingredients
• Overall perception of smokiness

As a result, two solutions can fulfil a similar technological function while delivering different sensory experiences.

Why are more ingredients and processes being reviewed?

Regulatory changes are driven by factors including new scientific evidence, safety assessments, public health considerations, and evolving food policies.

At the same time, consumers are paying closer attention to product composition, ingredient sourcing, health, and sustainability.

For brands, this creates an environment where reformulation can become necessary at different stages of a product's lifecycle.

Developing a structured methodology for managing these changes can help reduce timelines, compare alternatives more effectively, and protect product acceptance.

The real pain point is not replacing the ingredient. It is keeping consumers

An alternative may perform perfectly well in the laboratory and still create a different experience when it reaches consumers.

That is one of the main risks of any product reformulation project: meeting a new regulatory requirement only to discover that consumers like the new recipe less.

Reformulating blindly: the risk of losing flavour, acceptance, and sales

A formulation change can affect multiple attributes that influence how consumers evaluate a product:

• Aroma
• Flavour
• Colour
• Texture
• Intensity
• Persistence
• Overall perception
• Purchase intent

The relevance of each attribute depends on the product category and positioning. Internal teams may also interpret certain changes differently because they have an in-depth understanding of the original formulation and the technical objectives behind the project.

When the technology stays the same, but the sensory outcome changes

The smoke flavouring case provides a good illustration. A company may maintain its objective of delivering a specific smoky experience and still obtain a different sensory profile after changing the flavouring solution.

Intensity may change, new notes may emerge, or persistence may vary. The key question is whether consumers notice these changes and, more importantly, whether those changes affect how they evaluate the product. Product sensory validation helps answer these questions before launch.

Tight deadlines and pressure on R&D and Quality teams

A regulatory reformulation involves much more than changing a recipe. The process may include:

1. Identifying affected products
2. Reviewing current formulations
3. Searching for alternatives
4. Evaluating suppliers
5. Developing prototypes
6. Conducting stability testing
7. Carrying out sensory validation
8. Selecting the final formulation
9. Updating specifications and labelling
10. Preparing for launch

If consumer validation only takes place at the end of the process, an unfavourable result may require several stages to be repeated.

Integrating sensory evaluation throughout development makes it possible to prioritise the alternatives with the greatest potential before reaching the final stages.

Why is sensory analysis the answer to regulatory changes?

Sensory analysis adds information that technical testing cannot provide on its own: how consumers perceive and evaluate the product.

In a reformulation project, this information can be used to compare alternatives, identify relevant changes, and assess their impact on acceptance.

Discrimination testing: can consumers tell the difference?

Discrimination tests determine whether consumers can detect differences between products. In a reformulation project, they can be used to compare:

• The current formulation with the reformulated version
• Different replacement ingredients
• Different levels of an ingredient
• Different solutions for achieving the same sensory attribute

The first question is straightforward: can consumers detect the change? If they cannot, the brand has relevant evidence to support the decision to move forward. If they can, the next step is to determine how meaningful that difference is.

Acceptance testing: do consumers still like the product?

Detecting a difference does not necessarily mean that consumers will rate the new formulation less favourably. Acceptance testing makes it possible to measure liking and explore variables such as:

• Overall liking
• Preference
• Purchase intent
• Attribute ratings
• Differences between consumer groups

This information helps determine whether a sensory difference has a meaningful commercial impact.

Making decisions with data, not intuition

R&D expertise is essential when developing alternatives. Consumer feedback provides a complementary perspective.

When both sources of information are integrated into the process, companies can make decisions with a more complete understanding of the product.

Sensory validation provides evidence to select one formulation, reject another, or continue optimising an alternative.

In regulatory projects, this helps identify potential issues while there is still time to address them.

From regulatory obligation to product improvement opportunity

A regulatory requirement can create an opportunity to review a product from a broader perspective.

When a brand needs to modify a formulation, the project can also be used to compare alternatives that may improve cost, availability, composition, or sensory performance. In addition to replacing the affected ingredient, teams can evaluate:

• Cost of the new formulation
• Supply availability and stability
• Recipe complexity
• Sensory profile
• Ingredient list
• Potential for future reformulations

Sensory validation brings the consumer perspective into this comparison, helping prevent decisions based solely on internal criteria.

Reformulating effectively as a competitive advantage

When a regulation affects an entire category, all companies face similar pressure. The advantage can come from having a structured approach to the challenge.

A structured reformulation process makes it easier to identify alternatives, test prototypes, and understand consumer response before committing to a launch.

The learnings generated can also support future innovation and product development projects.

How Sensesbit helps food and beverage brands reformulate without risking consumer loyalty

Sensory validation can be integrated at different stages of the process, from the initial comparison of alternatives to the evaluation of the final formulation before launch.

Sensesbit helps teams design sensory studies, collect consumer data, and turn those results into actionable information for decision-making.

Validate reformulations with real consumers before launch

Brands can compare their current formulation with different alternatives and analyse the response of real consumers. Depending on the study objective, teams can measure:

• Whether consumers perceive differences
• Which formulation achieves the highest acceptance
• Which attributes explain those differences
• Whether the new recipe maintains preference
• How purchase intent changes

This brings the consumer into the decision-making process before the new formulation reaches the market.

From laboratory testing to business decisions, backed by objective data

Regulatory changes will continue to shape food and beverage product development. For R&D and Quality teams, the challenge is to adapt quickly while keeping product and brand risk under control.

That is why sensory validation should be part of the reformulation strategy from the earliest stages of the project.

With Sensesbit, teams can evaluate alternatives with real consumers, identify relevant differences, and support formulation decisions with data before launch.