NOM-051: Deadlines for Phases have been extended

August 11, 2025

Phase 3 for front-of-package labeling is postponed: more time to make adjustments

On July 31, the Secretary of Economy published an agreement extending Phase 2 for the front-of-package labeling system established in NOM-051. This extension is good news for the industry, which allows more time to update the labels and reformulate products if necessary.

What is the difference between Phases 2 and 3? 

Both phases require octagonal labels to be placed on products that contain excess nutrients (free sugars, saturated or trans fats, and sodium) that are added (not naturally found in the product) when they exceed legal limits.

The difference lies in determining which products need to have labels:

• Phase 2 (until 2027). Only those nutrients that were specifically added are evaluated. (For example: If only sodium is added, then only the sodium content will be evaluated, though the product may have naturally high levels of sugars or fats.)
• Phase 3 (as of 2028). Adding a single excess nutrient will lead to all of them being evaluated (even if they are natural).

What are the implications? 

The entry into force of Phase 3 will particularly affect products that are naturally dense in excess nutrients, even if they were previously perceived as healthy:

• Saturated fats: nuts, seeds, meats, and dairy, even if minimally processed.
• Sugars: juices, jams, dried fruits and other products derived from natural fruit, even if they don´t contain added sugar.
• Calories from starch: whole-grain breads, flours and other products derived from tubers and cereals.

In all these cases, adding a pinch of salt can lead to the overall evaluation, forcing products to implement the labels.

What to do? 

Starting now, companies should consider:

• Evaluating the total nutritional content of the product, not just what is added.
• Planning for reformulations if they wish to avoid Phase 3 labels.
• Adjusting the labels, designs, and packaging materials ahead of time.

The good news is that there is now some leeway until 2028 with this extension.