Tell Sec. Kennedy: Nanotech Shouldn’t Be “Generally Recognized As Safe”

Just like it did with GMOs, the Food & Drug Administration has let nanotech ingredients slip into our food through its “generally recognized as safe” loophole. Sec. Kennedy says he wants to end the GRAS loophole and he’s even used the most common nanotech ingredient, titanium dioxide, as an example of GRAS gone wrong—but he hasn’t said anything about nanotechnology (or genetic engineering).

TAKE ACTION: Tell Sec. Kennedy: Nanotech Shouldn’t Be “Generally Recognized As Safe”

Nanotech ingredients should have been regulated under Congress’s 1958 food additives law. This would have required each new nanotech ingredient to go through a rigorous premarket review to be approved or rejected based on scientific evidence, but in 2007, President George W. Bush‘s Food & Drug Administration turned the law on its head, announcing that, while it had the power to regulate nanotech ingredients as food additives, companies could treat them as “generally recognized as safe” unless or until the FDA made a decision on how to define nano.

That never happened.

A U.S. Government Accountability Office investigation published in 2010 found that engineered nanomaterials were entering the food supply as GRAS substances without the FDA's knowledge.

In 2014, President Barack Obama’s FDA answered these concerns by issuing a final guidance for industry on nanotechnology that stated the FDA was not aware of any food ingredient engineered on the nanometer scale for which there are generally available safety data sufficient to serve as the foundation to meet the GRAS criteria. In other words, the FDA said engineered nanomaterials weren’t GRAS, but that didn’t get nano ingredients off the market. If anything, Obama’s FDA made the GRAS loophole for nanotech even bigger. In 2016, it issued a Final Rule on Substances Generally Recognized as Safe where it affirmed the Clinton Era policy of not requiring manufacturers to submit their GRAS determinations to the agency.

On March 10, 2025, Health & Human Services Secretary Robert F. Kennedy, Jr., promised to close the “generally recognized as safe” (GRAS) loophole that allows dangerous food additives to enter the marketplace without premarket safety testing. This could mean ingredients made with nanotechnology might finally be safety tested as food additives!

TAKE ACTION: Tell Sec. Kennedy: Nanotech Shouldn’t Be “Generally Recognized As Safe”

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*SAMPLE TEXT TO ROBERT KENNEDY JR., SECRETARY OF THE U.S. DEPARTMENT OF HUMAN AND HEALTH SERVICES*

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Dear Secretary Kennedy,

Thank you for promising to close the “generally recognized as safe” (GRAS) loophole that allows dangerous food additives to enter the marketplace without premarket safety testing. I hope this means ingredients made with nanotechnology might finally be safety-tested as food additives!

Engineered nanoparticles are so small they can poke holes in our stomach lining, break into our cells, and cross our blood-brain barrier. This can trigger the body's inflammatory and immune responses, cause cells to die or become dysfunctional, and damage the brain. Impacts include allergic reactions, autoimmune disease, heart attack and stroke, cancer, and dementia.

More and more evidence of the health harms of nanotechnology is available each day. To start with, I encourage you to read “Beyond the promise: Exploring the complex interactions of nanoparticles within biological systems,” published in the Journal of Hazardous Materials in April 2024.

Despite the known risks, engineered nanomaterials are routinely used in drug delivery systems (the COVID vaccines’ lipid nanoparticles are just one recent example). Even worse, the Food & Drug Administration has allowed engineered nanoparticles in food, toothpaste, sunscreen, and other things we ingest and rub on our skin—all without any safety testing or labeling.

They’re even in infant formula! According to the Center for Food Safety, the FDA has known for several years that many infant formulas contain nanochemical additives that the agency has never approved. A study conducted by Arizona State University found hydroxyapatite and titanium dioxide nanoparticles in infant formula manufactured by four companies: Gerber, Enfamil, Well Beginnings, and Similac. These nanomaterials are common in non-organic food and are used for their brightening/whitening, anti-caking, and flow-enhancing properties.

In 2022, the European Union banned the most common nanotech ingredient, titanium dioxide. The FDA was petitioned to do the same in 2023, but hasn’t made a decision yet. I hope you’ve directed the FDA to respond to that right away.

Ultimately, what is needed is an FDA directive, announcing a moratorium on the use of nanotech ingredients in food unless or until they successfully complete the food additive review process.

Thank you for your attention to this urgent matter.

[Your Name]

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