Food Labeling

The FDA Finally Liberates French Dressing from 72-Year-Old Ingredient Mandates

Why? A better question was why they were ever involved in the first place.


The Food and Drug Administration (FDA) has decided to relax some of its strict rules and allow manufacturer innovation to run wild—if only in the world of French dressing.

On Thursday the FDA will publish a final rule change in the Federal Register that will revoke the 72-year-old "standard of identity" that mandates what ingredients need to be in French dressing in order for it to be legally marketed with that name.

The change was requested by the Association for Dressings and Sauces, a nearly 100-year-old trade group representing this creamy and/or zesty sector of the food industry. After a comment and evaluation period, the FDA determined "that the standard of identity for French dressing no longer promotes honesty and fair dealing in the interest of consumers and revoking the standard could provide greater flexibility in the product's manufacture, consistent with comparable, nonstandardized foods available in the marketplace."

Translation: nobody is being tricked by "fraudulent" bottles of French dressing and really the only thing the standards do is restrict innovation and creativity with what might be done with the flavor or contents.

French dressing, historically, contains tomatoes, oil, vinegar, and some other seasonings. At the time that the FDA established a mandated identity for French dressing in 1950, the new announcement notes, the government focused on just three types of salad dressings and mandated their identities in order to legally bear these labels. That's it. Now we live in the fancy world of 2022, where grocery shelves are full (well, theoretically full) of wild combinations of salad dressings your grandparents never even dreamed of. And these new dressings are not subject similar standards of identity.

The Association for Dressings and Sauces noted in its petition that all this delicious innovation and all those fancy choices happened precisely because those other dressings didn't have forced standards. The FDA agrees with this observation, seeing "a proliferation of nonstandardized pourable dressings for salads with respect to flavors (Italian, Ranch, cheese, fruit, peppercorn, varied vinegars, and other flavoring concepts) and composition (including a wide range of reduced fat, "light," and fat-free dressings)."

Again, consumers are not screaming in despair over the lack of government-mandated "identities" for all of these other dressings. There's no reason why French dressing should be singled out for stricter identity demands than other dressings.

This is all somewhat similar to a rule change from the FDA in 2020 to deregulate the content requirements for frozen cherry pies. When that rule change was announced, it might have appeared as though the FDA was giving frozen cherry pie makers permission to sell crappy products containing hardly any cherries to unsuspecting buyers. But the FDA noted that only frozen cherry pies were regulated with these restrictions, not other forms of frozen fruit pies, nor other fresh pies. And yet, consumers were not, in fact, being screwed over by substandard fruit contents of frozen apple or raspberry pies. Consumer power and influence (and more importantly, consumer choice and competition) has been enough to keep manufacturers honest.

There is a similar market response at work here with French dressing. The FDA notes in its final rule that French dressing manufacturers have standardized their products in a way that's even narrower than the FDA identity requirements in response to consumer demands. In other words, U.S. French dressing lovers want a tomato-based sauce with a sweet taste that is reddish-orange in color. French dressing manufacturers understand that this is what their consumers want and are giving it to them. Market forces, not the FDA, have standardized the contents of French dressing.

But the FDA's restrictions do keep these French dressing manufacturers from branching out in certain ways and innovating and testing new flavor profiles. This has caused the dressing to become "marginalized," according to the petition from the Association for Dressings and Sauces. They perhaps have a point. The deregulation seems funny precisely because French dressing has become such a cultural artifact that echoes a past era of food. I haven't had it since I was a child in the 1970s. Maybe manufacturers want to spice it up with some jalapeno or something, like they do with all the other salad dressings.

Even funnier than the idea of the FDA having ever regulated French dressing all this time is that nobody really cared to complain. The FDA reports getting "more than 20 comments" on the rule change. "Some comments appeared to have been submitted as part of a university course assignment," it notes. Most comments were supportive. A couple of commenters mistakenly believed that the FDA was going to ban the label of "French dressing" entirely and needed to be assured that was not the case.

Only one comment objected to dropping the rules over a belief that manufacturers might put more "fillers" in a product to make it cheaper. This is the frozen cherry pie argument again. Other pies were not constrained by FDA rules and yet weren't full of fillers to make them cheaper. The FDA also notes that the rule change wouldn't remove labeling requirements, so if French dressing were suddenly full of fillers (and one wonders what that would even look like for a dressing that's primarily tomatoes, sugar, vinegar, and vegetable oil) those fillers would have to be listed in the ingredients.

At long last the marketplace of ideas will come to the world of French dressing. Maybe it will be revitalized as a product. Maybe French dressing purists will reject changes. Whatever comes, the market is certainly a better place to determine what the dressing should contain than the offices of the FDA.

One final punchline about how long it takes for the FDA to do anything, no matter how inconsequential: The petition by the Association for Dressings and Sauces for deregulation was initially submitted to the agency in January 1998.