Aldi's 57 restricted ingredients vs. Texas SB 25's 44: where the two lists overlap

As of November 2026, 34 of Aldi's 57 restricted ingredients also appear on the Texas SB 25 warning list, and 33 of the 44 Texas entries are covered by Aldi. The gaps: sweeteners, preservatives, bakery emulsifiers.

The short answer

As of November 2026, 34 of the 57 ingredients Aldi US restricts in its private-label food (60%) also appear on the Texas SB 25 warning-label list, and 33 of the 44 Texas entries (75%) are covered by Aldi's list. Taken together, the two lists name 67 distinct substances. A supplier who formulates only to Aldi still misses 11 Texas entries, mostly bakery emulsifiers, bleached flour and interesterified oils. A supplier who formulates only to Texas still misses 23 Aldi entries, including four high-intensity sweeteners and seven preservatives.

Why this question matters now

Three ingredient deadlines land within about a year of each other:

Texas SB 25 requires a warning on food labels "developed or copyrighted on or after January 1, 2027" when the product contains one of 44 listed ingredients. The Texas Department of State Health Services (DSHS) finalized its implementing rule on February 20, 2026, and said any change to an existing label after January 1, 2027 counts as a label "developed."
Aldi US announced in April 2026 that it will remove 44 more ingredients from its private-label food, vitamin and supplement products by December 31, 2027. That brings its restricted list to 57, counting 13 ingredients it had already removed.
Walmart US said in October 2025 that it will remove synthetic dyes and 30 other ingredients from its private-brand foods by January 2027.

For a private-label supplier, the practical question is how much one reformulation can cover at once. Aldi and Texas both publish their lists in full, so this analysis compares those two. We could not read Walmart's full item list from a primary source, so it is not part of the count.

Where the lists overlap

The 34 Aldi entries that also appear on the Texas list fall into a few functional groups:

Colors (11 Aldi entries): FD&C Blue 1, Blue 2, Green 3, Red 3, Red 40, Yellow 5, Yellow 6, Orange B and Citrus Red, plus canthaxanthin and titanium dioxide. The certified colors are on Aldi's earlier, already-removed list. Texas lists the same dyes by name and also lists "certified food colors" as a category.
Flour treatment (6): azodicarbonamide, bromated flour, calcium bromate, potassium bromate, sodium stearyl fumarate and stearyl tartrate.
Processing aids (6 Aldi entries): DSS (dioctyl sodium sulfosuccinate), ficin, lye, sodium hydroxide, morpholine and propylene oxide.
Fats (3): partially hydrogenated oils, synthetic trans fatty acids and olestra.
Preservatives (3): BHA, BHT and propylparaben.
Others (5): sodium aluminum sulfate and potassium aluminum sulfate, synthetic diacetyl, anisole and toluene.

A product clean for Aldi's full list still has to clear the 11 Texas-only entries below.

What Texas lists that Aldi does not

These 11 Texas entries are not on Aldi's list:

acetylated esters of mono- and diglycerides
DATEM
lactylated fatty acid esters of glycerol and propylene glycol
bleached flour
potassium iodate
interesterified palm oil
interesterified soybean oil
sodium lauryl sulfate
thiodipropionic acid
Red 4
DMAA (dimethylamylamine)

Seven of the 11 are bakery and fat ingredients: three emulsifiers (DATEM and the acetylated and lactylated esters), bleached flour, potassium iodate (a dough oxidizer) and two interesterified oils. Bread, buns, tortillas, cakes and shortening-based fillings are the products where an Aldi-compliant formula is most likely to still trigger the Texas warning. Aldi does restrict a related emulsifier, "lactylated esters of mono and diglycerides." We did not count that as the same substance as the Texas entry. If you count it as a match, the figures become 35 of 57 and 34 of 44.

Note that the DSHS rule reads the statute more narrowly than the bare list suggests. Law-firm summaries of the final rule (Haynes Boone, Keller and Heckman) say DSHS treats ingredients that are GRAS or found safe by FDA or USDA as outside the rule, and that this includes bleaching ingredients used under federal rules. DSHS still treats all certified colors as covered. The same summaries say the Texas Attorney General is not bound by DSHS's reading. Whether a given DATEM or bleached-flour use triggers the warning is a question for a regulatory expert, not for a list comparison.

What Aldi restricts that Texas does not

These 23 Aldi entries are not on the Texas list:

Sweeteners (4): acesulfame K, advantame, cyclamates and neotame. Texas lists no sweeteners. This matters most for beverages, where acesulfame K is a common partner to sucralose in zero-sugar systems.
Preservatives (7): methylparaben, butylparaben, calcium sorbate, potassium bisulfite/bisulfate, potassium metabisulfite, potassium nitrate and potassium nitrite. The sulfites affect dried fruit and some juice and wine-based products. Nitrites and nitrates affect cured items.
Fat replacers and emulsifiers (4): Simplesse, caprenin, sucroglycerides, and lactylated esters of mono and diglycerides.
Processing aids and contaminants (5): bentonite, ethylene oxide, sodium ferrocyanide, talc and phthalates.
Others (3): brominated vegetable oil, MSG and foie gras.

Aldi's FAQ says the restriction applies "either as a direct ingredient or as part of a composite ingredient." So the check has to reach into sub-ingredient statements from flavor, seasoning and inclusion suppliers.

Practical guidance for formulators

Build to the union when you can. If a formula is headed to Aldi and will be sold in Texas, screen it against all 67 substances in one pass rather than running two separate reviews.
Bakery: start with the Texas-only list. DATEM, bleached flour and potassium iodate are the items an Aldi-clean bread is most likely to still contain. The acetylated and lactylated esters show up more in cakes, icings and whipped toppings. Enzyme systems, ascorbic acid and unbleached flour are the usual starting points. Validate volume, crumb and shelf life.
Beverages: start with the Aldi-only sweeteners. A zero-sugar beverage can pass Texas and still fail Aldi because of acesulfame K. Stevia, monk fruit and erythritol are on neither the Aldi nor the Texas list, but each changes the sweetness curve and aftertaste. Re-run sensory work.
Colors are the shared core. Colors exempt from certification, such as fruit and vegetable juice or spirulina extract, are outside the Texas color entries unless the statute names them. Two exempt colors are named on both lists: canthaxanthin and titanium dioxide. Confirm edge cases with a regulatory expert.
Track label dates, not just formulas. Under the DSHS rule, a label revised after January 1, 2027 is a new label. A routine artwork change could bring an unchanged formula into scope.
Mind the litigation. A federal court in American Beverage Association v. Paxton preliminarily enjoined enforcement of the warning on February 11, 2026, but only against the four plaintiff trade groups and their members. Texas appealed to the Fifth Circuit in March 2026 and filed its brief in August 2026. As of November 2026 we found no reported appellate decision. Companies outside those associations should get legal advice and not assume the injunction protects them.

SKS's food ingredient compliance checker screens common additives against seven US retailers' private-label rules, including Aldi. It covers most, not all, of Aldi's 57 entries and does not check Texas SB 25, so use the Texas-only list above for that. The food color additive compliance tool helps with the color portion. Both are decision support, not a buyer's confirmation or legal review.

How SKS analyzed this

We transcribed Aldi US's restricted-ingredient table, which lists 13 already removed plus 44 to remove by December 31, 2027, from Aldi's Ingredient Standards and newsroom pages as published in November 2026. We transcribed the 44 Texas SB 25 entries from the full lists in the Arnold & Porter and CIRS summaries of the statute, which match item for item. In Python, we mapped each entry to a substance key. Lye and sodium hydroxide were treated as the same substance, and Texas's "certified food colors" entry was matched to the nine certified colors on Aldi's list. Aldi's "FD&C Red No. 2 – Amaranth, Citrus red" entry was matched to Texas's Citrus Red 2. Near-matches with different chemical names, such as the two lactylated ester entries, were counted as different. Because Aldi lists lye and sodium hydroxide separately and Texas lists lye once, 34 Aldi entries map to 33 Texas entries. We counted overlaps in both directions and grouped the results by functional class. The counts depend on these mapping choices, and the DSHS rule's GRAS carve-out may narrow which Texas entries apply in practice.

Frequently asked questions

If my product meets Aldi's ingredient standards, does it avoid the Texas warning?

Not necessarily. Aldi's list covers 33 of the 44 Texas entries. The other 11, including DATEM, bleached flour and interesterified oils, need a separate check, and counsel should confirm how DSHS's GRAS carve-out applies.

Does Texas SB 25 restrict artificial sweeteners?

No. None of the 44 Texas entries is a sweetener. Aldi restricts acesulfame K, advantame, cyclamates and neotame, so sweetener changes in an Aldi project are driven by the retailer, not by Texas.

When does the Texas warning requirement start?

It applies to food labels developed or copyrighted on or after January 1, 2027. Under the DSHS final rule of February 20, 2026, a change to an existing label after that date counts as developing a label. Enforcement against members of the four plaintiff trade associations is enjoined while the Fifth Circuit appeal is pending.

When does Aldi's expanded list take effect?

Aldi says reformulated products will roll out in phases through December 31, 2027. The 13 earlier ingredients, such as certified colors, MSG and partially hydrogenated oils, are already removed.

Sources

"ALDI Eliminating an Additional 44 Ingredients from Private Label Food Assortment by the End of 2027," ALDI US, April 22, 2026 (updated September 2026). https://corporate.aldi.us/newsroom/news/aldi-eliminating-an-additional-44-ingredients
"Our Ingredient Standards," ALDI US. https://corporate.aldi.us/about-us/our-food-philosophy/our-ingredient-standards
"Aldi to remove 44 ingredients from private label assortment," Food Dive, April 27, 2026. https://www.fooddive.com/news/aldi-remove-44-ingredients-private-label/818472/
"Everything's Bigger in Texas — Including Its Regulation of Ultra-Processed Foods," Arnold & Porter, July 1, 2025. https://www.arnoldporter.com/en/perspectives/advisories/2025/07/texas-regulation-of-ultra-processed-foods
"Texas Updates Food Labeling Law: 44 Ingredients Require Warning Labels," CIRS Group, July 15, 2025. https://www.cirs-group.com/en/food/texas-updates-food-labeling-law-44-ingredients-require-warning-labels
"Court Enjoins Texas SB 25 Food Label Warning Requirement," Covington & Burling, February 12, 2026. https://www.cov.com/en/news-and-insights/insights/2026/02/court-enjoins-texas-sb-25-food-label-warning-requirement
"An Update on Warnings on Texas Food Labels: Administrative Rule Finalized Amid Ongoing Litigation and Injunction," Haynes Boone, March 7, 2026. https://www.haynesboone.com/news/alerts/an-update-on-warnings-on-texas-food-labels-administrative
"Texas Food Label Rule Finalized Despite Ongoing Litigation and Injunction," Keller and Heckman via National Law Review, March 27, 2026. https://natlawreview.com/article/texas-food-label-rule-finalized-despite-ongoing-litigation-and-injunction
"What ABA v. Paxton Means for State Food-Warning Label Laws," Center for Health Law and Policy Innovation, Harvard Law School, September 28, 2026. https://chlpi.org/news-and-events/news-and-commentary/food-law-and-policy/what-aba-v-paxton-means-for-state-food-warning-label-laws/
"Walmart to remove dozens of artificial ingredients from private label brands," Food Dive, October 2, 2025. https://www.fooddive.com/news/walmart-remove-artificial-dyes-ingredients-private-label/801835/

Published by SKS Nutrition. Explore the tools behind this research on SKS Nutrition AI.