A Smart Packaging Wake-Up Call? What CPG Brands Need to Know Now About Louisiana’s New Mandatory Disclosure Law

by Jack Bernier

Executive Summary: New regulations in Louisiana will require manufacturers to digitally disclose the presence of specified ingredients via smart labeling.  An on-pack QR code will be mandatory, and must link to a webpage directing users to FDA ingredient safety data.

Louisiana has enacted Senate Bill 14 (Act No. 463), a multi-pronged bill addressing food safety concerns which have recently come into prominence.  Specifically, Section 3 of the bill mandates the digital disclosure of certain ingredients in food products.  This introduces new labeling requirements for manufacturers, aiming to empower consumers with clearer, more accessible information about what they’re eating.

What Must Be Disclosed?

Under Section 3, any food product sold in Louisiana must be labeled if it contains one or more of 44 specified ingredients. These include:

Artificial Sweeteners & Additives

• Aspartame
• Sucralose
• Acesulfame potassium
• Olestra
• Diacetyl

Synthetic Oils & Fats

• Partially hydrogenated oils (PHOs)
• Interesterified palm and soybean oils
• Synthetic trans fatty acids

Artificial Dyes

• Red dyes 3, 4, 40
• Blue dyes 1, 2
• Yellow dyes 5, 6
• Green dye 3
• Citrus red dye 2

Preservatives & Stabilizers

• BHA (Butylated hydroxyanisole)
• BHT (Butylated hydroxytoluene)
• Propylparaben
• Thiodipropionic acid

Industrial Chemicals

• Azodicarbonamide (ADA)
• Toluene
• Morpholine
• Propylene oxide

Emulsifiers & Surfactants

• Sodium lauryl sulfate
• Stearyl tartrate
• Dioctyl sodium sulfosuccinate (DSS)

Flour & Baking Agents

• Bleached flour
• Bromated flour
• Calcium bromate

Certified Colors

• Any food color certified by the FDA

These ingredients have been flagged due to health concerns, regulatory scrutiny, or bans in other jurisdictions.

Digital Labeling Requirements

To comply with this new legislation, manufacturers must include a digital disclosure mechanism on product packaging:

QR Code Guidelines

• A visible QR code must appear on the label.
• Adjacent text must inform consumers that scanning the code reveals ingredient information.

Web Page & Disclaimer

• The QR code must link to a manufacturer-controlled webpage.
• The page must display the following disclaimer prominently:

“NOTICE: This product contains [insert ingredient here]. For more information about this ingredient, including FDA approvals, click HERE.”

• The “HERE” link must direct users to the FDA’s official food chemical safety page.

This approach blends physical labeling with digital transparency, allowing consumers to access real-time safety data and regulatory context.

Exemptions & Limitations

The law applies only to food and beverages intended for human consumption. It does not apply to:

• Drugs or dietary supplements regulated by the FDA
• Alcoholic beverages
• Food prepared and labeled in retail establishments
• Medical foods under federal definition
• Multiunit packages (only the outer container must comply)

These carve-outs help avoid regulatory overlap and reduce burdens on small-scale food providers.  Additionally, the law includes a federal preemption clause: if federal regulations become more restrictive, they will override the state law.

Timeline of Implementation

Section 3 establishes digital disclosure requirements for food manufacturers and restaurants, effective January 1, 2028.  This gives institutions and businesses time to adapt while signaling a long-term commitment to public health.

Why It Matters

Louisiana’s digital disclosure law reflects a growing demand for clarity in food labeling and a shift toward digital access to ingredient data. By requiring manufacturers to disclose potentially harmful substances, the law empowers consumers to make informed choices and encourages industry accountability.

As other states watch closely, Louisiana may be setting a precedent for nationwide reform in food labeling and digital disclosure policy.