Comment from Corn Refiners Association et al

This is a Comment on the Food and Drug Administration (FDA) Proposed Rule: Food Labeling: Revision of the Nutrition and Supplement Facts Labels

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June 2, 2014

Hon. Michael R. Taylor,
Deputy Commissioner, Office of Foods and Veterinary Medicine
Food and Drug Administration
10903 New Hampshire Ave
White Oak Building 1
Silver Spring, MD 20993

Dear Deputy Commissioner Taylor:

The undersigned food industry trade associations have committed in principle to funding qualitative and quantitative consumer perception research relevant to proposed changes in the Nutrition Facts Panel. We are writing to respectfully request a meeting with you at your earliest convenience to discuss our plans for such research.

We believe such consumer research is essential to measure likely consumer understanding of the proposed changes, behavioral response to the proposed changes and benefits of modifying the Nutrition Facts Panel. We submit that appropriate research should inform not only FDA, but the commenting public, as well.

Further, we have identified highly respected experts available to review the regulatory impact analysis accompanying the proposed rule, including an assessment of the extent to which reformulation is likely and the economic consequences of reformulation. We believe that work would result in recommendations for strengthening the regulatory impact analysis. As that work is dependent upon empirical data regarding consumer understanding and response, it must be performed subsequent to the consumer research referenced above and cannot be completed before the close of the extended comment period.

To assure the usefulness of the research to the rulemaking process, we seek FDA comments regarding our research plan. We are eager to discuss how we may obtain information that genuinely enriches the comment record and enables FDA to develop the best possible improvements in the Nutrition Facts Panel.

To schedule the meeting we request, please contact Andy Resnick, at or via phone at (202) 534-3501.


American Bakers Association
American Beverage Association
American Frozen Foods Institute
Corn Refiners Association
International Dairy Foods Association
National Confectioners Association



Comment from Corn Refiners Association et al

View Attachment:
Authors: cfsan

Comment Period Closed
Jun 2 2014, at 11:59 PM ET
ID: FDA-2012-N-1210-0155
Tracking Number: 1jy-8cg0-dt0g

Document Information

Date Posted: Jun 13, 2014
RIN: 0910-AF22
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Submitter Information

Category: Association - D0003