Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
Featured Stories
Food Northwest Challenges Proposed Definition of Ultra-Processed Foods
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WASHINGTON, Nov. 22 -- Food Northwest, Portland, Oregon, submitted a public comment letter to the U.S. Food and Drug Administration (FDA) challenging the agency's initiative to define "ultra-processed foods." The association, which comprises 230 firms ranging from small family-owned businesses to large multinational corporations, argues that the creation of a federal classification for ultra-processed foods (UPFs) may confuse consumers and detract from established dietary guidelines.
The association contends that defining UPFs at the federal level is not beneficial for public health. Food Northwest
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WASHINGTON, Nov. 22 -- Food Northwest, Portland, Oregon, submitted a public comment letter to the U.S. Food and Drug Administration (FDA) challenging the agency's initiative to define "ultra-processed foods." The association, which comprises 230 firms ranging from small family-owned businesses to large multinational corporations, argues that the creation of a federal classification for ultra-processed foods (UPFs) may confuse consumers and detract from established dietary guidelines.
The association contends that defining UPFs at the federal level is not beneficial for public health. Food Northwestasserts that consumer confidence in existing food standards would be undermined by the adoption of new categories lacking scientific consensus. They emphasize that dietary guidelines based on energy and nutritional content are sufficient tools for promoting better health outcomes among Americans.
Food Northwest highlights concerns regarding the reliance on observational studies that have small sample sizes and lack proper control groups. The organization argues that methods which do not connect food processing or ingredient presence directly to health outcomes should not shape public policy. They maintain that classifications stemming from systems like NOVA, initially developed for research in Brazil, are inconsistent and unsuitable for a regulatory framework in the United States.
In their statement, Food Northwest calls the subjective nature of existing definitions dangerous, noting that even among nutrition professionals, there is substantial inconsistency in classifying foods based on the NOVA framework. They claim such definitions could lead to dietary recommendations that potentially disregard affordable sources of nutrients resulting in increased food waste and less healthy choices.
The association further insists that traits like ingredient presence and processing methods, historically utilized without evidence of harmful health effects, should not dictate food categorization. Instead, they propose maintaining focus on nutrient and energy density to guide consumer choices effectively.
The organization has also voiced a desire for research meeting rigorous scientific standards to precede any regulatory actions concerning UPFs. Food Northwest's position reflects a broader apprehension that arbitrary government definitions could complicate food safety efforts and consumer decisions.
As the FDA continues its exploration of food classification systems, Food Northwest urges policymakers to rely on established dietary information rather than pursuing definitions that could diminish public understanding of nutrition in America. They emphasize that scientific evidence should precede any changes in food categorization, safeguarding consumers' access to nutritious foods.
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The letter was signed by:
Dave Dillon
President, Food Northwest
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5100
Defeat Malnutrition Today Urges FDA to Proceed Cautiously on Ultra-Processed Foods Definition
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WASHINGTON, Nov. 22 -- Defeat Malnutrition Today, a coalition representing over 120 members, submitted a public comment letter to the Food and Drug Administration regarding its Request for Information on Ultra-Processed Foods (UPFs). The organization commended the agency and the U.S. Department of Agriculture for their efforts to examine regulatory definitions of UPFs as a means to enhance national nutrition and public health outcomes.
In the letter, Defeat Malnutrition Today highlighted the importance of defining UPFs in a way that could improve the nutritional quality of food consumed by the
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WASHINGTON, Nov. 22 -- Defeat Malnutrition Today, a coalition representing over 120 members, submitted a public comment letter to the Food and Drug Administration regarding its Request for Information on Ultra-Processed Foods (UPFs). The organization commended the agency and the U.S. Department of Agriculture for their efforts to examine regulatory definitions of UPFs as a means to enhance national nutrition and public health outcomes.
In the letter, Defeat Malnutrition Today highlighted the importance of defining UPFs in a way that could improve the nutritional quality of food consumed by theAmerican public and help reduce diet-related diseases and malnutrition. The coalition emphasized that while this presents a promising opportunity, caution is essential in the process of definition.
The organization raised concerns about labeling food as "ultra-processed" based solely on a single ingredient's presence, which could lead to unintended consequences, especially regarding medical foods and specialized nutrition products developed to address malnutrition and other health conditions. For instance, Oral Nutrition Supplements (ONS), which are nutrient-dense products designed for specific dietary needs, play a crucial role in managing malnutrition. Defeat Malnutrition Today pointed out that using ONS has been shown to lower hospitalization rates and related medical expenses.
As the FDA and USDA consider the best approach to defining UPFs, the coalition encourages the agencies to rely on scientific evidence, taking into account both the nutritional value and intended use of various foods. They urged the need for a clear distinction between low-nutrient, heavily processed foods and specialized nutrition products, which are essential for health maintenance and recovery.
The comment letter underlines a critical moment in nutritional policy, as regulatory clarity could reshape how food products are perceived and consumed in the healthcare context. Defeat Malnutrition Today remains committed to advocating for a nuanced approach that prioritizes public health while respecting the complexities around nutrition. The coalition expressed gratitude for the opportunity to contribute to this discussion, reinforcing their involvement in fostering a food system that adequately addresses the challenges of malnutrition, particularly among older adults.
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The letter was signed by:
Bob Blancato
National Coordinator
Defeat Malnutrition Today
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5127
Clark Hill Public Strategies Raises Concerns Over Proposed Courier Regulations
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WASHINGTON, Nov. 22 -- Clark Hill Public Strategies (CHPS), Detroit, Michigan, has issued a public comment letter to the U.S. Department of State regarding proposed changes to the regulations surrounding the Hand-Carry Program, specifically addressing concerns with the current rules under 22 CFR Part 54. As an affiliate of a large international law firm, CHPS specializes in advocacy, policy, and regulatory guidance, and seeks to ensure that industry voices are heard in governmental processes.
In the letter, CHPS expresses its apprehension over the suggested transition to a "first-come, first-served"
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WASHINGTON, Nov. 22 -- Clark Hill Public Strategies (CHPS), Detroit, Michigan, has issued a public comment letter to the U.S. Department of State regarding proposed changes to the regulations surrounding the Hand-Carry Program, specifically addressing concerns with the current rules under 22 CFR Part 54. As an affiliate of a large international law firm, CHPS specializes in advocacy, policy, and regulatory guidance, and seeks to ensure that industry voices are heard in governmental processes.
In the letter, CHPS expresses its apprehension over the suggested transition to a "first-come, first-served"registration system for courier companies. The organization argues that this change could unfairly disrupt the established practices of proven operators who have consistently met the Department's standards. Observations from years of working with the industry indicate that such a shift would undermine a merit-based system that prioritizes reliability and compliance, potentially harming both service providers and their customers.
Additionally, the proposed requirement for courier companies to produce proof of business registration at local levels has raised alarms. CHPS states that many participants in the Hand-Carry Program are independent operators or small businesses that do not conform to a larger corporate structure. The organization argues that imposing such administrative hurdles could complicate operations without enhancing security or service outcomes.
The letter also critiques the "owner match" requirement, which mandates that ownership details align across local and federal registrations. This rule, according to CHPS, disregards the operational diversity within the courier sector and adds unnecessary layers of complexity. The organization suggests that the existing vetting processes are sufficient and that further documentation requirements may stifle smaller businesses that have played a vital role in the program's success.
Moreover, CHPS commended the Department's initiative in developing modern online passport renewal capabilities but cautioned against duplicating systems already successfully implemented by the private sector. They advocate for leveraging private-sector technology solutions to achieve efficiency, as mandated by the recent National Defense Authorization Act.
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Read full text of letter here: https://www.regulations.gov/comment/DOS-2025-0170-0021
Center for Science in the Public Interest Advocates for Clear Definition of Ultra-Processed Foods
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WASHINGTON, Nov. 22 -- The Center for Science in the Public Interest (CSPI) has submitted a public comment letter to the Food and Drug Administration (FDA) in response to the agency's request for information regarding the definition of ultra-processed foods (UPF). CSPI emphasizes the need for a consistent definition in order to address the escalating chronic disease crisis fueled by poor dietary choices prevalent in the United States.
The organization, a long-standing non-profit focused on improving public health through nutrition, highlights that over 350,000 deaths annually in the U.S. are
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WASHINGTON, Nov. 22 -- The Center for Science in the Public Interest (CSPI) has submitted a public comment letter to the Food and Drug Administration (FDA) in response to the agency's request for information regarding the definition of ultra-processed foods (UPF). CSPI emphasizes the need for a consistent definition in order to address the escalating chronic disease crisis fueled by poor dietary choices prevalent in the United States.
The organization, a long-standing non-profit focused on improving public health through nutrition, highlights that over 350,000 deaths annually in the U.S. areattributed to diet-related diseases such as cardiovascular disease and diabetes. Their letter points out that the American diet is largely dominated by industrially processed foods, which are often high in added sugars, sodium, and saturated fats-factors closely linked to various health issues. Notably, the average U.S. diet scores only 58 out of 100 on the Healthy Eating Index.
CSPI advocates for a robust operational definition of UPF that can be practically applied in regulatory policies. The letter argues that existing classification systems, including the Nova system, fall short of capturing the nuances of processed foods that correlate with health risks. The current absence of a universally accepted definition complicates efforts to design effective public health guidance and policies aimed at mitigating consumption of harmful food products.
The organization proposes that first, a definition of "processed foods" should be established, which would encompass foods that are not classified as unprocessed or minimally processed. Following this, UPF should be defined specifically as harmful processed foods that have been scientifically linked to adverse health outcomes. The definition would prioritize those foods characterized by high calorie density, excessive unhealthy nutrient density, and harmful ingredients.
Immediate actions are also recommended, including measures to strengthen front-of-package labeling requirements, implement cancer warnings on processed meats, and ensure stricter regulations on food additives. CSPI expresses a commitment to working with the FDA and other agencies to develop actionable guidelines that would propel the U.S. food supply toward a healthier paradigm without obstructing access to affordable foods.
CSPI's letter underscores a pressing need for the federal government to address health concerns associated with food choices effectively and equitably, particularly for vulnerable populations. The organization calls for a collective effort to define UPF in a way that facilitates meaningful regulatory action, ultimately aiming to enhance public health through better nutrition.
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The letter was signed by:
Eva Greenthal, MS, MPH
Senior Policy Scientist
egreenthal@cspi.org
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Aviva Musicus, ScD
Science Director
*
Anupama Joshi, MS
Vice President of Programs
*
Peter Lurie, MD, MPH
Executive Director and President
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5001
California Walnut Commission Opposes Restrictive Definition of Ultraprocessed Foods
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WASHINGTON, Nov. 22 -- The California Walnut Commission (CWC), Folsom, has submitted a public comment letter to the U.S. Department of Agriculture (USDA) and Food and Drug Administration (FDA) expressing concerns over a potential government-wide definition for ultraprocessed foods (UPF). The CWC, representing over 3,700 growers in California, emphasizes the importance of not framing processing as a negative factor when evaluating food.
CWC asserts that nearly all foods require some level of processing, which can provide essential public health benefits. With approximately seventy percent of walnut
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WASHINGTON, Nov. 22 -- The California Walnut Commission (CWC), Folsom, has submitted a public comment letter to the U.S. Department of Agriculture (USDA) and Food and Drug Administration (FDA) expressing concerns over a potential government-wide definition for ultraprocessed foods (UPF). The CWC, representing over 3,700 growers in California, emphasizes the importance of not framing processing as a negative factor when evaluating food.
CWC asserts that nearly all foods require some level of processing, which can provide essential public health benefits. With approximately seventy percent of walnutfarms in California being small businesses under 100 acres, the organization warns that punitive definitions could harm producers of nutritious options like walnuts, which are already under-consumed in the U.S. The Commission believes that focusing solely on processing methods may dissuade consumers from including nutrient-dense foods in their diets.
In its letter, CWC advises the FDA and USDA against categorizing foods based on processing levels, as it could have unintended consequences, such as discouraging consumption of walnuts and other beneficial products. The organization posits that a more effective approach would involve emphasizing nutrient density, similar to the FDA's existing "healthy" nutrient-content claim model.
The comment letter highlights the inadequacies of the widely cited NOVA classification system, which categorizes foods based solely on processing. Experts argue that this system fails to account for the healthfulness of certain processed foods, such as whole grains and dairy products. CWC points to international examples, noting that several countries have opted not to establish dietary guidance based on processing levels in favor of prioritizing nutrient content.
CWC urges both agencies to support policies that promote healthier eating without inadvertently penalizing nutrient-rich foods. Data indicates that while many Americans meet daily protein recommendations, a significant portion comes from sources high in saturated fats and sodium. Nut consumption, specifically walnuts, remains notably low among the population, necessitating fresh approaches to dietary recommendations.
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The letter was signed by:
Robert Verloop
CEO, California Walnut Commission
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4892
California Division of Occupational Safety & Health Raises Concerns Over Proposed Changes to Asbestos Standards
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WASHINGTON, Nov. 22 -- The California Division of Occupational Safety and Health (Cal/OSHA) has submitted a public comment letter to the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) voicing opposition to proposed revisions to asbestos safety standards. Cal/OSHA asserts that the revisions, outlined in the agency's docket, would pose a significant threat to worker health and safety.
Cal/OSHA emphasizes that the changes would reduce existing protections and compromise the safety of workers who are routinely exposed to asbestos, a known carcinogen. The agency argues
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WASHINGTON, Nov. 22 -- The California Division of Occupational Safety and Health (Cal/OSHA) has submitted a public comment letter to the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) voicing opposition to proposed revisions to asbestos safety standards. Cal/OSHA asserts that the revisions, outlined in the agency's docket, would pose a significant threat to worker health and safety.
Cal/OSHA emphasizes that the changes would reduce existing protections and compromise the safety of workers who are routinely exposed to asbestos, a known carcinogen. The agency arguesthat the proposals contravene the Occupational Safety and Health Act of 1970, which mandates that worker standards must ensure no impairment of health even with regular exposure to hazardous materials.
The letter details specific areas of concern regarding the proposed revisions, including the deletion of scenario-specific work descriptions for respiratory protection usage. Cal/OSHA contends that the existing language emphasizes the need for respirators in situations such as maintenance or emergencies, which would be rendered inadequate if replaced with vague references to a general respiratory protection standard.
Another critical point raised by Cal/OSHA is the proposed removal of HEPA filter requirements. This change would enable the use of less effective respirators, increasing the likelihood of worker exposure to harmful asbestos fibers, thereby elevating health risks. Moreover, the agency strongly opposes a proposal to allow non-tight-fitting respirators, arguing that such devices would leave workers vulnerable as they do not provide a proper seal, thus increasing exposure to airborne asbestos.
Cal/OSHA also highlights the importance of mandatory respirator training for employees working with asbestos. The proposed elimination of this training requirement is viewed as reckless, especially given the level of misunderstanding that workers may have about the risks of asbestos exposure.
The agency's letter underscores that while OSHA aims to harmonize its various standards, it should reconsider the implications of generalizing protections that protect a significant percentage of workers. By prioritizing worker safety, Cal/OSHA urges OSHA to maintain strict standards specifically tailored to handle the distinct dangers posed by asbestos exposure instead of diluting them with broader regulations.
Given the severe health risks associated with asbestos, the Division remains steadfast in advocating for rigorous protections to prevent further risks to workers.
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The letter was signed by:
Dean Mochrie, CAC
Senior Safety Engineer
Cal/OSHA Asbestos and Carcinogen Unit
*
Eric Berg,
Deputy Chief of Health
Cal/OSHA
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Read full text of letter here: https://www.regulations.gov/comment/OSHA-2025-0024-0045
Bank Policy Institute, Clearing House Association Urge Treasury to Clarify Digital Asset Illicit Finance Rules
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WASHINGTON, Nov. 22 -- The Bank Policy Institute and Clearing House Association, New York, have submitted a public comment letter to the U.S. Department of the Treasury addressing significant issues regarding illicit finance risks in the digital asset ecosystem. The letter emphasizes the necessity for a clear regulatory framework that will allow financial institutions to effectively tackle these risks while promoting innovation.
The Associations express strong support for the goals of the Bank Secrecy Act (BSA) and advocate for a regulatory environment where both traditional financial institutions
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WASHINGTON, Nov. 22 -- The Bank Policy Institute and Clearing House Association, New York, have submitted a public comment letter to the U.S. Department of the Treasury addressing significant issues regarding illicit finance risks in the digital asset ecosystem. The letter emphasizes the necessity for a clear regulatory framework that will allow financial institutions to effectively tackle these risks while promoting innovation.
The Associations express strong support for the goals of the Bank Secrecy Act (BSA) and advocate for a regulatory environment where both traditional financial institutionsand digital asset-native companies share comparable obligations regarding anti-money laundering (AML) and customer due diligence (CDD). They highlight the need for consistent regulations guided by the principle of "same activity, same risk, same rules," a system that would enable fair competition and enhance financial stability.
In their comments, the Associations recommend that the Treasury provide clarity on which activities trigger Know Your Customer (KYC) responsibilities and how innovative tools can assist compliant practices. Notably, they argue against the requirement for prolonged parallel runs with legacy systems, as this imposes an undue financial burden on institutions seeking to adopt novel technologies. Furthermore, they stress the importance of enabling information sharing among institutions to strengthen AML/CFT frameworks.
The letter discusses the complexities posed by decentralized finance (DeFi) and the various risks related to transactions involving non-KYC'd wallets. The Associations advocate for regulatory clarity to guide financial institutions in mitigating risks associated with such wallets and leveraging blockchain analytics tools to enhance compliance efforts.
Additionally, the Associations underscore the potential of artificial intelligence (AI) in detecting illicit finance. They propose that U.S. regulators facilitate the exploration and integration of AI/ML technologies into compliance frameworks to improve overall risk detection capabilities while ensuring that regulatory guidelines remain adaptable to emerging technologies.
On the subject of digital identity, the Associations urge the Treasury to provide direction on incorporating digital identity verification tools to improve the customer onboarding process, thereby reducing identity-related fraud. They call for a national approach towards digital identity systems that bolsters privacy protections and fits within existing regulatory requirements.
In closing, the Associations express their willingness to collaborate with the Treasury and other stakeholders in creating an effective regulatory environment that addresses illicit finance risks while fostering innovation in the digital asset sector. Their comprehensive letter outlines a roadmap for achieving a balanced regulatory framework that supports the growth and security of the evolving digital asset landscape.
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The letter was signed by:
Rodney Abele
Director of Regulatory & Legislative Affairs
The Clearing House Association
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Clara Kim
Senior Vice President
Bank Policy Institute
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Read full text of letter here: https://www.regulations.gov/comment/TREAS-DO-2025-0070-0241
American Meat Science Association Addresses FDA on Ultra-Processed Foods
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WASHINGTON, Nov. 22 -- The American Meat Science Association (AMSA), Kearney, Missouri, has submitted a public comment letter to the Food and Drug Administration (FDA) in response to its request for information regarding Ultra-Processed Foods (UPFs). The organization expressed concern over the potential misclassification of meat products due to vague terminology related to food processing.
In its comments, AMSA highlighted the organization's expertise and extensive history in meat science. The association shared that its members include leading scientists dedicated to understanding meat ingredients,
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WASHINGTON, Nov. 22 -- The American Meat Science Association (AMSA), Kearney, Missouri, has submitted a public comment letter to the Food and Drug Administration (FDA) in response to its request for information regarding Ultra-Processed Foods (UPFs). The organization expressed concern over the potential misclassification of meat products due to vague terminology related to food processing.
In its comments, AMSA highlighted the organization's expertise and extensive history in meat science. The association shared that its members include leading scientists dedicated to understanding meat ingredients,safety, processing techniques, and the overall quality of meat products. They believe precise terminology is vital, particularly as the term "ultra-processed" can lead to misconceptions about the health benefits associated with meat. AMSA stresses that the term does not accurately represent meat products, which provide essential nutrients and are produced through regulated processes that ensure safety and quality.
AMSA pointed out that the regulatory standards established by the U.S. Department of Agriculture Food Safety and Inspection Service (FSIS) and the FDA regarding Standards of Identity (SOI) are crucial for consumer confidence. The organization argues that these standards define the composition and labeling requirements for meat products, ensuring that consumers understand what they are purchasing. This regulatory framework has been in place since 1939 and has evolved to protect public health and promote clarity in food labeling.
Addressing questions posed in the FDA's RFI, AMSA provided clarity on common meat-related terms and emphasized the complexities of meat processing. The association shared that the processing of meat is a continuum that involves various physical and biochemical methods aimed at enhancing safety, quality, and efficiency. They warned that a reductionist view of processed foods risks mischaracterizing meats that hold substantial nutritional value.
Furthermore, AMSA highlighted the need for transparency in ingredient labeling, recognizing that all food additives used in meat products undergo safety evaluations by both the FDA and FSIS. The letter underscored the significance of accurately portraying the roles of these ingredients in ensuring consumer safety while maintaining food quality.
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The letter was signed by:
Christi Calhoun, Ph.D.
Scientific Communication Resource Officer
American Meat Science Association
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4847
