Not legal advice. This summary is provided for engineering and operations teams configuring Closient. The statutory text controls. Verify the ingredient list, effective dates, and exemption scope against the enrolled bill and consult Texas counsel before relying on this page for compliance.
What the statute requires
Under SB 25 (codified at Tex. Health & Safety Code §431.0816 — verify codification against the enrolled text), a food product offered for retail sale in Texas that contains any of the listed ingredients must, on or after the labeling effective date, bear a label that includes:- A scannable code — URL, QR code, barcode, or other electronic means — on the package, that
- Resolves to information identifying the presence of the listed ingredient for the product
The 44-ingredient list
The Texas list overlaps substantially with Louisiana SB 14 but is not identical. The three ingredients that appear on the Texas list and not on the Louisiana list are highlighted below.The list below is a working summary for engineering reference. The enrolled bill text is the controlling source — verify every entry before treating any list as canonical, and re-verify after each legislative session in case of amendments.
The three Texas-specific entries are flagged inline. Note that Texas omits a small number of entries that appear on Louisiana’s list (notably azodicarbonamide); a brand operating in both states should not assume one list is a superset of the other.
Effective dates
The Texas labeling deadline is 12 months earlier than Louisiana’s (Jan 1, 2027 vs Jan 1, 2028). Brands shipping to both states should plan to be label-compliant for Texas first; once the resolver-rule wiring is in place for TX, extending to LA is configuration, not engineering.
Exemptions
The Texas exemptions track LA SB 14 with one notable addition (USDA-regulated meat and poultry, where federal pre-emption applies):- Drugs regulated under the federal Food, Drug, and Cosmetic Act
- Dietary supplements regulated as such under federal law
- Alcoholic beverages regulated by the TTB / Texas Alcoholic Beverage Commission
- Retail-prepared food (food prepared and offered for immediate consumption at retail)
- Medical foods as defined under federal law
- USDA-regulated meat and poultry (federal pre-emption under the Federal Meat Inspection Act / Poultry Products Inspection Act)
Enforcement
Enforcement authority sits with the Texas Department of State Health Services and is integrated with the broader Texas food-labeling enforcement framework. Penalties follow the statutory schedule for food-labeling violations under Tex. Health & Safety Code Chapter 431. Consult Texas counsel for the current penalty structure and any rulemaking from DSHS implementing the SB 25 provisions. There is no federal pre-emption argument for the disclosure obligation itself, though specific listed ingredients regulated under USDA jurisdiction (meat and poultry products) are carved out as above.Configuring Closient for TX SB 25
The configuration is identical to LA SB 14 — the disclosure surface is the samegs1:ingredientsInfo link type, the QR target is the same https://www.closient.com/01/{gtin} resolver URL. The Texas statute does not require a separate safety-information surface the way Louisiana does, so gs1:safetyInfo is optional for Texas-only compliance but recommended if you are shipping to both states.
Related
- US State Ingredient Disclosure overview
- Louisiana SB 14 — the sibling Louisiana law (overlapping list, later effective date, explicit “manufacturer control” requirement)
- Manufacturer Control — architectural rationale for the resolver-based pattern
- TX SB 25 bill page (Texas Legislature)
Not legal advice. Verify all statutory references and ingredient list entries against the enrolled bill. Consult Texas counsel before relying on this page for compliance.