The standard of identify for French Dressing has been revoked.
After years of petitioning from the Association for Dressings and Sauces (ADS), the Food and Drug Administration has announced that it is finally revoking the standard of identify for French dressing. The rule goes into effect 30 days after the publication of The Federal Register (01/13/2022), which is February 12th, 2022.
The Federal Register states that the standard "no longer promotes honesty and fair dealing in the interest of consumers" and that removing the standard of identity "will provide greater flexibility in the product’s manufacture, consistent with comparable, non-standardized foods available in the marketplace." This revocation will allow manufacturers to alter the ingredients of their product — for example, the amount of oil used — and add additional flexibility to new recipes for French dressing.
Here's a little history on regulating the product that the publication provides:
When the standard of identity was established in 1950, French dressing was one of three types of dressings we identified (15 FR 5227). We generally characterized the dressings as containing a fat ingredient, an acidifying ingredient, and seasoning ingredients. The French dressing standard allowed for certain flexibility in manufacturers’ choice of oil, acidifying ingredients, and seasoning ingredients. Tomatoes or tomato-derived ingredients were among the seasoning ingredients permitted, but not required. Amendments to the standard since 1950 have permitted the use of additional ingredients, such as any safe and suitable color additives that impart the color traditionally expected (39 FR 39543 at 39554-39555). Most, if not all, products currently sold under the name “French dressing” contain tomatoes or tomato-derived ingredients and have a characteristic red or reddish-orange color. They also tend to have a sweet taste. Consumers appear to expect these characteristics when purchasing products represented as French dressing. Thus, it appears that, since the establishment of the standard of identity, French dressing has become a narrower category of products than prescribed by the standard. These products maintain the above characteristics without a standard of identity specifically requiring them.
If you are a listener of our podcast, Aw, Would You Look At The Time, this may sound familiar. In 2019, Allegra and I dedicated an episode to figure out why the ADS had launched a movement to deregulate French dressing.
In that episode, we were able to get statements from both the FDA and the ADS on the deregulation movement. We also spoke with the owner of Mullen's Dressings, Jeff Shaner, about how he was forced to rename an almost century-old French dressing recipe to "Imitation French Dressing," in order to adhere to the FDA standards.
After years of petitioning (according to the Federal Register, the ADS has been asking for the revocation since 1998), the day has finally come.
There were some voices against the dressing standard revocation. One complaint stated that manufacturers may instead use more “fillers” in the product so that it is less expensive to make. The FDA decided to move forward with the proposal despite such claims, noting that "manufacturers must comply with the ingredient labeling requirements in 21 CFR 101.4. Therefore, consumers will still be informed about the ingredients in the French dressing they purchase."
So what will deregulation of French dressing bring to the United States? Only time will tell. Back in 2019, we asked Jeff Shaner if he would change the naming convention of his French dressings if it were to be deregulated. He answered, "Probably not at this point because people have been used to the word 'Imitation French' for almost 60 years now, so I think it would probably just confuse people if we tried to do that."
Perhaps we will start seeing French dressing in trendy salad joints like Sweetgreen or Just Salad, or we'll have more interesting options in the dressing aisle of the grocery store (prediction: Cajun spice French dressing).
P.S. You can get your own AWYLATT French Dressing sticker, seen in the above photo, here.
