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GRAS Compliance · State Disclosure

The federal GRAS regime is over.
State disclosure starts now.

New York's Food Safety and Chemical Disclosure Act (AB 1556) gives food and beverage manufacturers twelve months to file structured GRAS disclosures into a public database. California, New Jersey and Pennsylvania are next, with diverging formats. PRODEEN's GRAS-Ready package — fixed price per ingredient, human-verified outcome — clears every state's regime from one canonical record.

The clock is running. AB 1556 passed the New York Assembly 106–32 on April 21, 2026. Once Governor Hochul signs, the law takes effect in twelve months. Supplier evidence collection alone takes 60–90 days; the cheapest moment to start is now.
Built for food & beverage teams disclosing across NY · CA · NJ · PA · and the 100+ state food chemistry bills tracked nationwide
The shift

After 68 years, GRAS just stopped being a federal question.

Self-affirmed GRAS notification was the operating model since 1958. New York replaced it with a public disclosure regime in April 2026. California, New Jersey and Pennsylvania have parallel bills moving. What looked like one filing is becoming a continuous, multi-state data discipline.

01

Multi-state divergence is structural

Each state defines covered entity, GRAS scope, reporting fields and timelines slightly differently. National manufacturers will need four versions of overlapping evidence within 24 months.

02

The reporting unit is SKU × ingredient × state

Mid-sized brands are looking at thousands of disclosure entries. Large CPG at orders of magnitude more. Spreadsheet-and-analyst is not a viable architecture.

03

The disclosed data is public and queryable

NYSDAM publishes a searchable database. NGOs, plaintiffs' firms and journalists will index it. Weak GRAS narratives become public risk surfaces, not private inadequacies.

By the numbers

The deadline most companies haven't internalised.

12 mo
From signature to first NY filing
≤100
Employee threshold — the only exemption
4 states
NY, CA, NJ, PA — diverging reporting formats
100+
State-level food chemistry bills tracked
How PRODEEN works

Six automation playbooks. One canonical record. Human-verified output.

PRODEEN's GRAS-Ready capability is built from six Prodeen automation playbooks that chain together — from horizon scanning the legislative landscape to delivering a filing-ready packet for each state, signed off by a regulatory expert before delivery.

🛰️

Multi-State GRAS Horizon Scan

Continuous monitoring of NY, CA, NJ, PA and the 100+ state food chemistry bills nationally — tagged against your ingredient and SKU portfolio.

📋

GRAS Ingredient Inventory

Ingest your SKU master, identify in-scope self-affirmed GRAS substances, flag gaps before NYSDAM does. Becomes the spine for every filing.

🤝

GRAS Supplier Outreach

Automate evidence collection across 30–80 suppliers. Templated questionnaires, structured ingestion, normalised into one canonical record.

📑

GRAS Evidence Dossier Builder

For each ingredient: substantial consumption history, GRAS basis narrative, supporting data and methods. AI-drafted, human-reviewed, audit-trailed.

📤

GRAS State Filing Generator

Map the canonical record onto NY, CA, NJ, PA filing formats. Build once; export as many times as states require.

🛡️

Public-Disclosure Risk Review

Pre-publication review by regulatory experts. Weak basis narratives flagged for reformulation, supplier substitution or counsel review — before they go public.

Built for the people who carry this

Three audiences, three operating realities, one data layer.

Ingredient suppliers · Co-mfrs

Win the customer questionnaire wave

Your CPG customers will demand GRAS evidence within weeks. Build the canonical record once; respond to every customer, every state, automatically. Anchor account: IFF.

Mid-market F&B

The regulatory team you can't afford to hire

No in-house regulatory leader? Outside counsel quoting six figures per state? PRODEEN runs your GRAS function — fixed price per ingredient, every state, human-verified output.

Large CPG

Make your regulatory team 5× more leveraged

Sits alongside PLM, QMS and SAP via API. State-rule engine maps canonical evidence onto every state. Senior scientists return to product innovation.

Why PRODEEN, not the alternatives

Compliance is the entry point. The data layer is the asset.

Outside counsel files for one state. Generic GRC platforms have no food-domain ontology. Generic LLMs cannot produce audit-ready output without human regulatory review. PRODEEN is purpose-built for this regime.

VS · Outside counsel $80–200K per state, files once, no data layer

One canonical record. Every state. Forever.

Build evidence once; export it into every state's format as those laws come online. Counsel writes the basis narrative; PRODEEN owns the data and the audit trail.

VS · Generic GRC platform Workflow-only, no food ontology

Food-specific schema, baked in.

Ingredient × supplier × state is a domain-specific data model. We've built it. Generic compliance tools haven't.

VS · Generic LLM (ChatGPT, Claude) Plausible draft, no regulatory grounding

Human-verified outcome, not AI output.

Every disclosed packet is reviewed and signed off by a Prodeen regulatory expert before delivery. Auditable inference log. No model training on your data. Ever.

Pricing

Fixed price per ingredient. Outcome guaranteed.

We don't price on seats or features. We price on the work — a filing-ready, human-verified packet for each ingredient in each state. If NYSDAM rejects a PRODEEN-produced filing for any reason traceable to our work, we re-do it at no charge.

Quickstart

Up to 10 ingredients

NY only · 30-day turnaround
  • Fixed price per ingredient
  • Full evidence dossier & basis narrative
  • Human regulatory expert sign-off
  • Filing-ready packet for NYSDAM
Strategic

50+ ingredients · all 4 states

Annual subscription · ongoing maintenance
  • Custom MSA with data-handling commitments
  • BYOK encryption & SOC 2 Type II
  • Public-disclosure risk review by default
  • Continuous multi-state horizon scan
Frequently asked

Questions buyers ask before booking a demo.

Who has to file under New York's GRAS disclosure law?

Any food or beverage manufacturer that sells products containing self-affirmed GRAS ingredients in New York. The only exemption is for independently owned businesses with 100 or fewer employees.

When does the New York GRAS disclosure law take effect?

AB 1556 passed the Assembly on April 21, 2026 and the Senate on March 23, 2026. It takes effect one year after Governor Hochul's signature.

What about California, New Jersey and Pennsylvania?

Each has parallel bills with different reporting fields and timelines. PRODEEN's state-rule engine maps your canonical evidence onto each state's format, so you build the data once and file as many times as needed.

What data do we have to share with PRODEEN?

SKU and ingredient master data, supplier identities, and any historical GRAS dossiers you hold. We do not require formulation-level proprietary data. Customer data is never used to train models — period. Per-tenant isolation, BYOK encryption and SOC 2 Type II are available for enterprise tiers.

Is this a replacement for outside counsel?

No. Counsel writes the GRAS basis narrative and provides legal judgment. PRODEEN owns the data layer that counsel works from — and that powers every subsequent filing in every other state. We are complementary, not a replacement.

What does "human-verified outcome" mean?

Every disclosed packet PRODEEN produces is reviewed and signed off by a regulatory expert before delivery. If a state regulator rejects a filing for reasons that trace back to our data or basis narrative, we redo the work at no charge.

What about the banned additives — Red Dye 3, potassium bromate, propylparaben?

AB 1556 prohibits the manufacture, distribution and sale of food containing those three substances in New York. PRODEEN flags any SKU containing them across your catalogue, so reformulation or recall planning starts before enforcement does.

Run a free GRAS gap analysis

Pick five of your products. We map them against AB 1556's reporting fields and the parallel CA / NJ / PA bills, and show you exactly what filing-ready looks like.

Try Prodeen Free

Talk to a regulatory expert

20 minutes. Walk through your portfolio. Get a fixed-price scope for your first NY filing — and a roadmap to the other three states.

Book a 20-min call →

This page is informational and is not legal advice. Manufacturers should consult qualified counsel for filing decisions. © 2026 PRODEEN.