Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
Featured Stories
Concerned Women for America Backs DOT Changes to Sex-Based Terminology in Drug Testing
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WASHINGTON, Dec. 2 -- Concerned Women for America (CWA) has expressed support for proposed changes to sex-based terminology and procedures within the U.S. Department of Transportation's "Procedures for Transportation Workplace Drug and Alcohol Testing Programs" (RIN 2105-AF28). In a public comment letter, the organization emphasized that these amendments are vital for maintaining the clarity of federal regulations in relation to the biological distinctions between men and women.
CWA conveyed its view that the characterization of sex should adhere to immutable definitions grounded in scientific
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WASHINGTON, Dec. 2 -- Concerned Women for America (CWA) has expressed support for proposed changes to sex-based terminology and procedures within the U.S. Department of Transportation's "Procedures for Transportation Workplace Drug and Alcohol Testing Programs" (RIN 2105-AF28). In a public comment letter, the organization emphasized that these amendments are vital for maintaining the clarity of federal regulations in relation to the biological distinctions between men and women.
CWA conveyed its view that the characterization of sex should adhere to immutable definitions grounded in scientificunderstanding, asserting that biological sex should not be overridden by personal claims of gender identity. They believe it is essential for federal law and policy to explicitly recognize the binary nature of sex as objectively determined, reinforcing that acknowledgment is key to protecting the dignity and privacy of individuals.
The organization acknowledged the previous administration's commitment to uphold women's dignity through policies that affirm their biological classification, referencing an initiative designed to protect women in diverse areas such as healthcare, education, and sports. CWA stated that the administration's stance aligns with its broader objective to affirm sex-based distinctions to ensure that women have adequate protections in all public and private sectors.
Moreover, CWA highlighted the importance of these proposed regulations in restoring and maintaining clear distinctions between male and female for effective identification, documentation, treatment, and enforcement. They argued that without such clarity, the implementation of federal programs could falter. The organization criticized the influence of what they termed "fabricated terminology" associated with modern gender ideology, describing it as subjective and prone to misuse, which jeopardizes legal protections grounded in sex.
CWA is calling upon the Department of Transportation to expedite the finalization of this supplement to RIN 2105-AF28, asserting that achieving its intended objectives will contribute significantly to accuracy and consistency in regulations. The organization believes that such policies are necessary not only for the integrity of transport workplace programs but also for broader implications related to sex and gender within government frameworks.
Concerned Women for America remains committed to advocating for policies that they believe will affirm and protect the unique rights of women, emphasizing the importance of scientifically accurate definitions in federal regulations.
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Read full text of letter here: https://www.regulations.gov/comment/DOT-OST-2021-0093-0499
American Pistachio Growers Urge FDA To Exclude Nuts From Ultra-Processed Food Classification
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WASHINGTON, Dec. 2 -- The American Pistachio Growers (APG), Fresno, California, has submitted a public comment letter to the Food and Drug Administration (FDA) regarding the classification of ultra-processed foods (UPFs). In this letter, APG has strongly advocated for the exemption of pistachios from being labeled as ultra-processed, a classification they argue could mislead consumers regarding the health benefits of these nuts.
APG, which represents over 850 members from farms primarily in California, Arizona, and New Mexico, emphasized the rapid growth of the American pistachio industry, now
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WASHINGTON, Dec. 2 -- The American Pistachio Growers (APG), Fresno, California, has submitted a public comment letter to the Food and Drug Administration (FDA) regarding the classification of ultra-processed foods (UPFs). In this letter, APG has strongly advocated for the exemption of pistachios from being labeled as ultra-processed, a classification they argue could mislead consumers regarding the health benefits of these nuts.
APG, which represents over 850 members from farms primarily in California, Arizona, and New Mexico, emphasized the rapid growth of the American pistachio industry, nowvalued at approximately $1.9 billion. The organization works toward advancing nutritional awareness, health research, legislative advocacy, and marketing efforts to promote the consumption of pistachios. Their letter details extensive research showcasing the numerous health benefits of pistachio consumption, including its role as a complete protein and its positive impacts on heart health, blood glucose control, and weight management.
The organization cautioned the agency that misclassifying nutritious foods like pistachios as UPFs could diminish consumer confidence and lead to reduced consumption of these healthful snacks. It highlighted that pistachios possess unique nutritional qualities and should not be categorized alongside foods that are heavily processed and lack beneficial nutrients.
In its response to various queries posed by the agency, APG suggested that exemptions should be made for raw agricultural commodities and minimally processed foods. They explained that certain processing methods, such as roasting, do not fundamentally alter the health attributes of pistachios. Additionally, APG underscored the importance of defining UPFs in a way that would avoid discouraging the consumption of beneficial foods, as an overly broad classification could inadvertently include items that are vital to a balanced diet.
Furthermore, the letter emphasized that the nutritional density of foods, including factors such as protein quality, should play a crucial role in their classification. By advocating for a science-based approach, APG aims to ensure that foods delivering essential nutrients are not mistakenly reclassified as unhealthy options.
As discussions around the UPF classification continue, APG urges the FDA to approach this issue with careful consideration of both consumer health implications and the integrity of the food supply chain. The organization remains committed to promoting the health benefits of pistachios and hopes to facilitate more informed dietary choices among consumers nationwide.
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The letter was signed by:
Zachary Fraser
President & CEO
American Pistachio Growers
ZFraser@americanpistachios.org
559.475.0435
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Cadee Condit
Vice President, Government Affairs
American Pistachio Growers
CCondit@americanpistachios.org
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4980
Barry University School of Law Environmental & Earth Law Clinic Supports Proposed Rule to Protect Southern Hognose Snake Under Endangered Species Act
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WASHINGTON, Dec. 2 -- The Barry University School of Law Environmental and Earth Law Clinic, Orlando, Florida, has submitted a public comment letter to the Fish and Wildlife Service urging for the finalization of a proposed rule to list the Southern Hognose Snake as a threatened species. This proposed action comes in response to the ongoing decline in this species' population, with the clinic emphasizing its vital role in the longleaf pine ecosystem.
The Environmental and Earth Law Clinic acknowledges the effectiveness of the Endangered Species Act, crediting it for preventing the extinction of
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WASHINGTON, Dec. 2 -- The Barry University School of Law Environmental and Earth Law Clinic, Orlando, Florida, has submitted a public comment letter to the Fish and Wildlife Service urging for the finalization of a proposed rule to list the Southern Hognose Snake as a threatened species. This proposed action comes in response to the ongoing decline in this species' population, with the clinic emphasizing its vital role in the longleaf pine ecosystem.
The Environmental and Earth Law Clinic acknowledges the effectiveness of the Endangered Species Act, crediting it for preventing the extinction ofover 99 percent of listed species. In their letter, the clinic expressed support for the U.S. Fish and Wildlife Service's determination that the Southern Hognose Snake, or Heterodon simus, warrants protection under Section 4(d) of the Act due to threats such as habitat loss, climate change, and predation.
The Southern Hognose Snake has seen a dramatic decline in its range and population, having lost a significant portion of its historical habitats. According to the Service's findings, the longleaf pine ecosystems, which once spanned over 90 million acres, have drastically reduced to less than 3 million acres today. The clinic pointed out that this habitat is crucial not just for the Southern Hognose but also supports a diverse array of other species.
In their submission, the clinic articulated several key threats impacting the Southern Hognose Snake. Road mortality, habitat fragmentation, and the introduction of non-native species contribute to the species' vulnerability. Additionally, climate-related changes pose further challenges, potentially altering available habitats and food sources.
The proposed protective regulations include prohibitions against various harmful actions, including harassment, harm, and illegal trade of the Southern Hognose Snake. The clinic argues that these measures are essential for preventing further population declines and ensuring the long-term survival of the species.
Barry University's Environmental and Earth Law Clinic emphasized the importance of collaboration among federal and state agencies, private landowners, and conservationists to successfully restore and protect habitats vital to the Southern Hognose Snake's survival. They urged the Service to take decisive action in implementing the proposed rule and encourage ongoing conservation efforts.
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The letter was signed by:
Barry University School of Law Environmental and Earth Law Clinic
Prepared by Emilie Bailey, Emma Berman, Serena Sapp, and Emily Inboden
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Read full text of letter here: https://www.regulations.gov/comment/FWS-R4-ES-2025-0210-0197
Healthy Food America Executive Director Urges FDA To Adopt NOVA Classification For Ultra-Processed Foods
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WASHINGTON, Dec. 2 -- James Krieger, executive director of Healthy Food America, Seattle, Washington, submitted a public comment letter to the Food and Drug Administration regarding its request for information on Ultra-Processed Foods (UPFs). The official contended that growing and convincing evidence linking UPF consumption to health harms is sufficient to merit regulatory and policy action to reduce exposure to these products.
The academic stated that a large body of cross-sectional and prospective studies, along with randomized trials, demonstrates an association between UPF consumption and
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WASHINGTON, Dec. 2 -- James Krieger, executive director of Healthy Food America, Seattle, Washington, submitted a public comment letter to the Food and Drug Administration regarding its request for information on Ultra-Processed Foods (UPFs). The official contended that growing and convincing evidence linking UPF consumption to health harms is sufficient to merit regulatory and policy action to reduce exposure to these products.
The academic stated that a large body of cross-sectional and prospective studies, along with randomized trials, demonstrates an association between UPF consumption andelevated risk of chronic diseases, including cardiovascular and metabolic disease, certain cancers, and mental health disorders. The comment noted that these studies found consumption adversely affects physiologic pathways, contributing to increased body weight and hypertension. Given that more than 50% of calories consumed in the U.S. come from UPFs, the available evidence clearly supports taking regulatory action, the executive director argued.
The primary recommendation was for the FDA to adopt the NOVA classification system as the best processed food classification system for use with the U.S. food supply. The expert asserted that an evidence-based definition must start with NOVA because it has been validated in epidemiologic and clinical studies with respect to adverse health outcomes. The system identifies UPFs based on the presence of marker ingredients--a set of cosmetic and non-culinary additives--regardless of their mass or position in the ingredient list. The agency was advised that general flavors should be used as markers, but only certified colors should be counted.
The comment further stated that nutritional content should not be the marker for UPFs, though nutrient consideration can serve as a complementary approach to identify unhealthy foods or allow exemptions for otherwise healthy products. The Clinical Professor Emeritus noted that using processing criteria to identify UPFs is impractical unless the FDA mandates public disclosure of the type and extent of processing at the product level. The term "UPF" should be retained due to public familiarity, the comment concluded, urging the agency to focus on a comprehensive strategy that addresses the problem instead of blaming certain foods.
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The letter was signed by:
James Krieger, MD, MPH
Clinical Professor Emeritus, University of Washington School of Public Health
Executive Director, Healthy Food America
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4949
Foundation for Defense of Democracies Urges Commerce Dept. to Prioritize American AI Exports Over China
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WASHINGTON, Dec. 2 -- The Foundation for Defense of Democracies has issued a public comment letter to the U.S. Department of Commerce urging the agency to streamline and prioritize American artificial intelligence (AI) exports. The organization believes that this initiative presents a prime opportunity for the United States to reinforce its technological leadership over China while fostering innovation that can ensure global stability and prosperity.
The letter outlines the unique advantages of the U.S. AI ecosystem, which integrates top-tier semiconductors, advanced cloud-computing capabilities,
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WASHINGTON, Dec. 2 -- The Foundation for Defense of Democracies has issued a public comment letter to the U.S. Department of Commerce urging the agency to streamline and prioritize American artificial intelligence (AI) exports. The organization believes that this initiative presents a prime opportunity for the United States to reinforce its technological leadership over China while fostering innovation that can ensure global stability and prosperity.
The letter outlines the unique advantages of the U.S. AI ecosystem, which integrates top-tier semiconductors, advanced cloud-computing capabilities,and robust software resources alongside a supportive regulatory environment and substantial financial infrastructure. These components are deemed essential for driving commercial opportunities, all while underscoring America's alliances and military strengths. The organization highlights concerns regarding China's attempts to acquire U.S. AI technologies through illicit means, emphasizing the need for the Commerce Department to support American firms in protecting their innovations.
To safeguard national security while promoting AI exports, the Foundation advocates that the Commerce Department focus on partnerships with frontline democracies. Such collaborations, it argues, would not only enhance military capabilities but would also optimize resource allocation within the defense sector, distinguishing between trusted allies and authoritarian regimes. Partnerships with countries such as Israel and Ukraine are specifically cited as having the potential to enhance American military operations through the integration of battle-tested AI applications.
Additionally, the organization emphasizes the importance of cybersecurity in the export process. It advises that the Commerce Department implement stringent standards for cybersecurity, physical security, and ownership disclosure for companies seeking to export AI technology. This includes requiring comprehensive evaluations of foreign investments and adherence to U.S. economic security practices, which aim to mitigate risks from adversarial actions.
As the global AI landscape evolves and China strives to bolster its own capabilities, the Foundation asserts that the United States must act decisively to maintain its leadership. By prioritizing exports to nations that align with U.S. values and security interests, the Commerce Department can create robust partnerships and secure advantages against rival nations. The organization expressed optimism that its input could influence future policy decisions, enhancing not just the U.S. position in AI but also global security dynamics.
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The letter was written by:
Jack Burnham, Research Analyst, FDD's China Program
Craig Singleton, Senior Director and Senior Fellow, FDD's China Program
Leah Siskind, Director of Impact and AI Research Fellow
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Read full text of letter here: https://www.regulations.gov/comment/ITA-2025-0070-0013
Fair Finance Watch Opposes Charter Application for Bridge National Trust Bank
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WASHINGTON, Dec. 2 -- Fair Finance Watch (FFW), New York, has submitted a public comment letter to the Office of the Comptroller of the Currency (OCC) expressing opposition to the application for chartering Bridge National Trust Bank. The organization raised concerns over the potential implications for community banking and compliance with existing regulations.
FFW's letter highlights worrying claims that the proposed bank, associated with Stripe, is attempting to withhold fundamental policies that are crucial for transparency and privacy compliance. The organization is urging the OCC to extend
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WASHINGTON, Dec. 2 -- Fair Finance Watch (FFW), New York, has submitted a public comment letter to the Office of the Comptroller of the Currency (OCC) expressing opposition to the application for chartering Bridge National Trust Bank. The organization raised concerns over the potential implications for community banking and compliance with existing regulations.
FFW's letter highlights worrying claims that the proposed bank, associated with Stripe, is attempting to withhold fundamental policies that are crucial for transparency and privacy compliance. The organization is urging the OCC to extendthe comment period, indicating that a lack of public insights could negatively impact the assessment of whether the bank will adequately meet the needs of local communities.
The letter also emphasizes the necessity for a thorough examination under the Community Reinvestment Act (CRA). FFW articulated that it is imperative for regulators to assess how Bridge National Trust Bank intends to support low- and moderate-income neighborhoods, a critical obligation for all financial institutions. The group contends that the proposed bank's application includes indications that it would be exempt from CRA assessments, a stipulation that FFW strongly disputes.
Further raising alarms, FFW mentioned ongoing issues surrounding Strip's privacy history, referencing a court case where claims of privacy violations have surfaced against the company. They contextualize this with a broader critique of Stripe's ambitions in the fintech space, particularly highlighting their latest blockchain initiative, which some analysts believe could perpetuate corporate monopolies rather than create meaningful financial innovation.
FFW's public comment pushes for accountability, insisting on public access to the bank's internal policies and compliance measures. They criticize the current regulatory environment for considering proposals that might eliminate public notice and opportunity for community input regarding banks' applications to expand services. The group argues that the elimination of such requirements would undermine the CRA's core intent and risk sidelining community interests.
In conclusion, Fair Finance Watch demands public hearings regarding the application, expressing that the OCC must take into account the historical context of financial regulation and community needs in order to ensure equitable outcomes. As scrutiny over the bank's charter application intensifies, the outcome remains uncertain, signaling a pivotal moment in community bank oversight and financial industry regulations.
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The letter was signed by:
Matthew R. Lee, Esq.
Fair Finance Watch
PO Box 130222
Chinatown Station
NY NY 10013
718-716-3540
lee@fairfinancewatch.org
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Read full text of letter here: https://www.regulations.gov/comment/OCC-2025-0603-0003
Ex-DOT IG Soskin Submits Feedback on DOJ Firearms Rights Rule
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WASHINGTON, Dec. 2 -- Ex-Transportation Inspector General Eric J. Soskin submitted a public comment letter to the U.S. Department of Justice outlining critical feedback regarding its proposed rulemaking aimed at restoring firearms rights to individuals previously barred by federal law. This comment comes in the wake of a notice of proposed rulemaking issued by the DOJ on July 22, 2025, which intends to establish criteria for determining eligibility for relief from federal firearms disabilities.
The proponent of the letter emphasizes the necessity of refining the proposed rule to better align with
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WASHINGTON, Dec. 2 -- Ex-Transportation Inspector General Eric J. Soskin submitted a public comment letter to the U.S. Department of Justice outlining critical feedback regarding its proposed rulemaking aimed at restoring firearms rights to individuals previously barred by federal law. This comment comes in the wake of a notice of proposed rulemaking issued by the DOJ on July 22, 2025, which intends to establish criteria for determining eligibility for relief from federal firearms disabilities.
The proponent of the letter emphasizes the necessity of refining the proposed rule to better align withthe constitutional rights recognized in landmark Supreme Court cases, such as District of Columbia v. Heller and New York State Rifle & Pistol Association v. Bruen. The letter argues that while the initiative is commendable, it could inadvertently perpetuate ongoing constitutional rights violations by placing obstacles in the way of eligible individuals seeking restoration of their Second Amendment rights.
Key suggestions include the implementation of a timeline for processing applications for relief, a mechanism for status updates, and the reduction of presumptions against relief that currently may hinder individuals who pose no genuine threat to public safety. The analysis points to the need for a more nuanced approach when assessing past criminal offenses that might affect eligibility, particularly with regards to non-violent offenses.
The letter also critiques the proposed rule's handling of state firearm-related convictions, arguing that it could penalize individuals who reside in states with stringent firearm laws that do not align with broader interpretations of Second Amendment rights. Notably, the author calls for a reconsideration of how individuals with established trustworthiness-such as law enforcement officers-are treated under this proposed rule.
Furthermore, the letter raises concerns about the proposed subsection allowing for arbitrary revocation of granted relief without due process. It suggests that any revocation must be preceded by a fair hearing, where individuals can contest the reasoning for their relief being rescinded.
As discussions around the restoration of Second Amendment rights progress, the letter underscores the importance of ensuring that the regulations introduced not only align with constitutional standards but also safeguard the rights of individuals against potential bureaucratic overreach. The author expresses hope that the DOJ will consider these recommendations to promote a more equitable process in the final rulemaking.
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Read full text of letter here: https://www.regulations.gov/comment/DOJ-LA-2025-0004-1306
Indiana Soybean Alliance Raises Concerns Over Ultra-Processed Food Classification
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WASHINGTON, Nov. 25 -- The Indiana Soybean Alliance Membership & Policy Committee, Indianapolis, has submitted a public comment letter to the U.S. Department of Health and Human Services and U.S. Department of Agriculture addressing recent discussions surrounding the classification of ultra-processed foods (UPF). The ISA emphasizes the importance of clarity in defining UPF, arguing that an overly broad classification could unfairly group nutritionally beneficial products with less healthy foods.
In its letter, ISA highlighted the healthful properties of soybean oil, particularly high oleic soybean
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WASHINGTON, Nov. 25 -- The Indiana Soybean Alliance Membership & Policy Committee, Indianapolis, has submitted a public comment letter to the U.S. Department of Health and Human Services and U.S. Department of Agriculture addressing recent discussions surrounding the classification of ultra-processed foods (UPF). The ISA emphasizes the importance of clarity in defining UPF, arguing that an overly broad classification could unfairly group nutritionally beneficial products with less healthy foods.
In its letter, ISA highlighted the healthful properties of soybean oil, particularly high oleic soybeanoil, which has made Indiana the leading producer of high oleic soybeans in the United States. The organization pointed out that soybean oil is low in saturated fat and contains heart-healthy monounsaturated fat, qualifying for health claims by the Food and Drug Administration (FDA). This oil is not just an important ingredient in various packaged goods but is also a staple in cooking, providing numerous nutritional benefits.
ISA expressed concern that food classification systems, particularly the NOVA classification, may inadequately reflect the healthfulness of certain foods. Many items considered ultra-processed, such as fruit-flavored yogurt and plant-based milks, can be nutrient-dense, while less processed foods may be lacking in nutritional value. The organization cautioned that public perceptions influenced by a faulty categorization of foods could lead to unnecessary doubts about safe and widely-used ingredients like seed oils.
Amid changing consumer attitudes toward processed foods, ISA cited a recent survey indicating that the majority of Americans do not actively avoid seed oils and consider them acceptable for consumption. The organization also referenced research indicating that higher intake of plant-based oils is associated with lower mortality rates related to cancer and cardiovascular diseases. These findings suggest that processing methods do not inherently determine dietary value.
As Indiana farmers continue to advocate for the benefits of high oleic soybean oil, ISA underscored the necessity for policies based on nutrient composition rather than vague classifications tied to processing methods. The organization emphasizes the contribution of high oleic soybean oil not only to health but also as a resource that provides economic support to farmers.
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The letter was signed by:
Courtney Kingery | CEO
Indiana Soybean Alliance
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5110
IDARE LLC Supports AI Export Program to Boost U.S. Leadership, Responsible Tech Use Abroad
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WASHINGTON, Nov. 25 -- IDARE LLC, Houston, Texas has submitted a public comment letter to the U.S. Department of Commerce providing input on the agency's Full-Stack AI Export Program established under Executive Order 14320. With annual revenues between $1 million and $2 million and a team of 20 to 50 employees, the company specializes in developing and exporting advanced artificial intelligence (AI) platforms aimed at sectors including Oil & Gas, Power & Utilities, Government, and Healthcare. The organization believes that the AI Export Program could enhance U.S. leadership in AI while promoting
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WASHINGTON, Nov. 25 -- IDARE LLC, Houston, Texas has submitted a public comment letter to the U.S. Department of Commerce providing input on the agency's Full-Stack AI Export Program established under Executive Order 14320. With annual revenues between $1 million and $2 million and a team of 20 to 50 employees, the company specializes in developing and exporting advanced artificial intelligence (AI) platforms aimed at sectors including Oil & Gas, Power & Utilities, Government, and Healthcare. The organization believes that the AI Export Program could enhance U.S. leadership in AI while promotingresponsible technology use in foreign markets.
According to the company, partner nations stand to gain access to reliable, U.S.-developed AI technologies that can lead to safer operations and improved decision-making in critical areas. The company offers two primary AI platforms, 'AI Easy' and 'KnowVerse AI', both of which are fully designed and developed in Houston. These platforms are aimed at delivering predictive analytics and autonomous AI solutions to enhance operational efficiencies across various sectors.
The company has identified several foreign markets that demonstrate strong potential for their AI exports, including the United Arab Emirates, Saudi Arabia, and India. They also suggest that federal support through export financing, political risk insurance, and partnerships via U.S. embassies could significantly boost export opportunities in these priority regions.
The letter highlights the necessity for the Full-Stack AI technology package to include various components that support real-world deployments. These include specific additions such as digital-twin models and integration frameworks tailored to industrial environments. The company emphasizes that clarifying the scope of the technology stack will ensure that proposals adequately represent the capabilities needed for actual implementation in critical infrastructure.
Additionally, the organization advocates for industry-led consortia within the program, recommending clear guidelines on governance structures and membership criteria to facilitate high-quality AI export packages. This guidance would promote stability and collaboration among both large and smaller firms, ensuring that they all meet requisite security and performance standards.
In their response, the company underscores that partnering with U.S. firms will provide foreign countries with trustworthy AI solutions while simultaneously bolstering U.S. competitiveness in the global market. By facilitating the export of secure and high-quality AI technologies, the Department can help reduce dependence on AI products from geopolitical rivals.
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The letter was signed by:
Dr. Khairul Chowdhury
CTO, IDARE LLC
Address: 11251 Northwest Frwy, STE 310,
Houston, TX-77092, USA
Email: kchowdhury@idare.io
Phone: +1 713 884 6390
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Read full text of letter here: https://www.regulations.gov/comment/ITA-2025-0070-0015
Florida Peanut Producers Association Raises Concerns About Ultra-Processed Foods Definition
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WASHINGTON, Nov. 25 -- The Florida Peanut Producers Association (FPPA), Marianna, has issued a public comment letter to the U.S. Department of Health and Human Services and U.S. Department of Agriculture addressing concerns over the definitions of ultra-processed foods. The letter follows a Request for Information on this topic published by the Food and Drug Administration on July 25, 2025, which has raised critical discussions surrounding food classifications.
In the letter, the FPPA emphasizes that an oversimplified definition of "ultra-processed" could have negative implications for public
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WASHINGTON, Nov. 25 -- The Florida Peanut Producers Association (FPPA), Marianna, has issued a public comment letter to the U.S. Department of Health and Human Services and U.S. Department of Agriculture addressing concerns over the definitions of ultra-processed foods. The letter follows a Request for Information on this topic published by the Food and Drug Administration on July 25, 2025, which has raised critical discussions surrounding food classifications.
In the letter, the FPPA emphasizes that an oversimplified definition of "ultra-processed" could have negative implications for publichealth. They argue that a thorough consideration of a food's nutrient density and its overall health impact should be integral to any regulatory definitions. Peanut products, including peanuts and peanut butter, are highlighted as affordable and versatile sources of nutrition that can support health outcomes.
The organization points to substantial scientific evidence linking peanut consumption to a reduced risk of heart disease, cancer, and diabetes. The FPPA urges that the nutritional benefits of peanuts should be recognized, irrespective of whether they are consumed whole or in ground form. They stress the need for science-based guidelines that prioritize the nutritional composition and health value of food products, rather than relying on the degree of processing as the primary metric for classification.
Advocating for an approach focused on nutrient density and measurable health outcomes, the FPPA believes that such a framework will facilitate balanced, evidence-based dietary recommendations for consumers, thereby enhancing public health initiatives. They caution against relying on overly broad classifications that might mislead consumers about the health implications of their dietary choices.
In conclusion, the Florida Peanut Producers Association has called on the FDA and USDA to consider these recommendations seriously. They expressed appreciation for the opportunity to contribute to a discussion that could shape dietary guidelines and influence consumer behavior regarding nutrition. The FPPA remains dedicated to promoting both the economic and nutritional value of Florida-grown peanuts while educating consumers about healthy lifestyle choices.
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The letter was signed by:
Brittany Green
Executive Director
brittany@flpeanuts.com
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4849
Demos Opposes DHS Proposal to Use SAVE System for Voter Registration Verification
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WASHINGTON, Nov. 25 -- Demos, New York, has filed a public comment letter in opposition to the Department of Homeland Security's proposal to modify the Systematic Alien Verification for Entitlements Program System of Records (SAVE system). The letter argues that the proposed updates, which aim to include verification of U.S. citizenship for voter registration, pose serious risks to voter rights and data privacy.
Demos has highlighted that the SAVE system was originally designed to process applications for government benefits based on immigration status, not to function as a voter eligibility verification
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WASHINGTON, Nov. 25 -- Demos, New York, has filed a public comment letter in opposition to the Department of Homeland Security's proposal to modify the Systematic Alien Verification for Entitlements Program System of Records (SAVE system). The letter argues that the proposed updates, which aim to include verification of U.S. citizenship for voter registration, pose serious risks to voter rights and data privacy.
Demos has highlighted that the SAVE system was originally designed to process applications for government benefits based on immigration status, not to function as a voter eligibility verificationtool. The organization contends that utilizing the system in this manner could lead to widespread disenfranchisement. According to Demos, the suggested changes to the SAVE system would improperly repurpose sensitive Social Security data from millions of individuals without their consent, potentially violating the Privacy Act of 1974.
The organization raised concerns about the accuracy and reliability of the SAVE system for voter eligibility checks. It noted that the system is built on point-in-time data, which may contain outdated or erroneous information. States utilizing this system have already begun purging voter rolls, but face challenges in accurately verifying voter eligibility, increasing the likelihood of wrongful disenfranchisement.
Demos pointed out that the risks are particularly acute for derivative citizens born to American citizens abroad and naturalized citizens whose records have not been updated in the SAVE system. The organization emphasized that communities of color, often disproportionately affected by inaccuracies in data, may find themselves at higher risk of having their voting rights undermined.
Furthermore, Demos criticized the DHS proposal as a "solution in search of a problem," asserting that claims of widespread noncitizen voting have been consistently debunked. The organization emphasized that the utilization of Social Security data in this context not only raises substantial privacy concerns but could also compromise the integrity of the electoral process.
Demos urges the agency to halt any plans to leverage the SAVE system for voter eligibility verification purposes, warning that such actions could exacerbate existing inequities in voter access and create unjust hurdles for eligible voters. The call to action from Demos reflects a broader concern about maintaining the integrity of the democratic process while safeguarding individual privacy and civil rights.
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Read full text of letter here: https://www.regulations.gov/comment/USCIS-2025-0337-0818
Cranberry Institute Advocates for Nutrient-Dense Classification in Ultra-Processed Foods Definition
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WASHINGTON, Nov. 25 -- The Cranberry Institute (CI), Carver, Massachusetts, has issued a public comment letter to the Food and Drug Administration (FDA) regarding the proposed definition of ultra-processed foods (UPFs), emphasizing the need for a nutrient-dense approach in labeling food products. The organization, representing approximately 90% of U.S. cranberry growers, asserts that the designation of certain cranberry products as UPFs could confuse consumers and contradict existing nutrition policies.
In the letter, the Cranberry Institute urged federal agencies to ensure that any future definition
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WASHINGTON, Nov. 25 -- The Cranberry Institute (CI), Carver, Massachusetts, has issued a public comment letter to the Food and Drug Administration (FDA) regarding the proposed definition of ultra-processed foods (UPFs), emphasizing the need for a nutrient-dense approach in labeling food products. The organization, representing approximately 90% of U.S. cranberry growers, asserts that the designation of certain cranberry products as UPFs could confuse consumers and contradict existing nutrition policies.
In the letter, the Cranberry Institute urged federal agencies to ensure that any future definitionof UPFs recognizes the nutritional contributions of cranberry products. The organization pointed out that cranberries and related products are sources of bioactive compounds that support heart and urinary tract health. Notably, the CI highlighted that products like sweetened dried cranberries and 27% cranberry juice cocktail should not be categorized as ultra-processed, as both have been acknowledged under the FDA's "healthy" claim framework.
The letter criticized the narrow focus on processing methods when classifying foods, arguing that a classification based on nutrient density is essential. It stressed that cutting, drying, and juicing are crucial methods for ensuring food safety and maintaining nutritional quality. By solely evaluating foods based on their processing, the agency risks mischaracterizing nutrient-rich products like cranberries and may inadvertently discourage fruit consumption among consumers.
Additionally, the Cranberry Institute referenced recent research indicating that the health benefits associated with fruit consumption extend beyond individual sugars to the whole fruit, including its fiber and nutrient content. The organization believes this perspective should inform FDA's approach to defining UPFs, suggesting that nutrient-dense foods with added sugars can still play a role in healthy diets.
Moreover, the CI called for policy clarification in the UPF definition, recommending a note that allows limited added sugars to enhance the palatability of naturally tart fruits, like cranberries, without designating them as ultra-processed. This adjustment would align with the FDA's "healthy" framework while promoting healthier dietary patterns.
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The letter was signed by:
William C. Frantz
Executive Director
Cranberry Institute
www.cranberryinstitute.org
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5028
American Olive Oil Producers Association, California Olive Oil Council, Olive Oil Commission of California Call for Clear Definition of Ultra-Processed Foods
Carter Struck
WASHINGTON, Nov. 25 -- The American Olive Oil Producers Association, Fresno, and California Olive Oil Council and Olive Oil Commission of California, both of Clovis, have submitted a public comment letter to the Food and Drug Administration (FDA) regarding the agency's request for information on ultra-processed foods (UPFs). Representing hundreds of American extra virgin olive oil (EVOO) growers and producers, these organizations emphasize that EVOO is critical for promoting health and combating diet-related chronic diseases in the United States.
The stakeholders commend the FDA's "Make America
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WASHINGTON, Nov. 25 -- The American Olive Oil Producers Association, Fresno, and California Olive Oil Council and Olive Oil Commission of California, both of Clovis, have submitted a public comment letter to the Food and Drug Administration (FDA) regarding the agency's request for information on ultra-processed foods (UPFs). Representing hundreds of American extra virgin olive oil (EVOO) growers and producers, these organizations emphasize that EVOO is critical for promoting health and combating diet-related chronic diseases in the United States.
The stakeholders commend the FDA's "Make AmericaHealthy Again" initiative aimed at reducing chronic illnesses linked to diet. They argue that while UPFs currently constitute over half the calorie intake for U.S. adults and children, a precise, science-based definition of these foods is essential. Their correspondence contends that UPFs are often characterized by high levels of saturated fat, sugar, and salt but lack nutritional value. Therefore, the organizations advocate for a comprehensive definition that considers both the methods of food processing and their nutritional qualities.
The letter highlights various food processing classification systems, noting that current models, including the widely used Nova system, do not sufficiently address the need for holistic definitions that account for nutritional quality. While acknowledging some definitions classify EVOO as minimally processed, the organizations assert that this categorization can misrepresent the health implications of different oils.
The group argues that products like EVOO, high in nutrients and health benefits, should not be labeled as UPFs simply due to minimal processing techniques, such as the use of natural gases for preservation. These methods enhance the nutritional quality of food rather than diminish it, fostering the consumption of healthier dietary options.
Furthermore, the letter points out that a clear distinction must be made between EVOO and refined oils, which undergo extensive processing that strips away beneficial compounds and introduces harmful elements. The organizations stress that the classification of foods, including the nuances of ingredient processing, should be reevaluated to reflect the health implications for consumers accurately.
In conclusion, the U.S. Olive Oil Industry advocates for scientifically based nutritional guidelines to facilitate informed consumer decisions and support public health. They express appreciation for the ongoing work by the FDA to create effective policies and look forward to contributing to initiatives that align with the goals of healthier American diets.
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The letter was signed by:
Kimberly Houlding
President and CEO
American Olive Oil Producers Association
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Suzanne Moreau
Executive Director
California Olive Oil Council
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Todd Sanders
Executive Director
Olive Oil Commission of California
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5122
ALAIAB Submits Comment to FDA Expressing Reservations Over Ambiguity in Ultra-Processed Foods Definition
Carter Struck
WASHINGTON, Nov. 25 -- The American Institute of Food Industry and Agricultural Biotechnology (ALAIAB), San Jose, Costa Rica, has submitted a public comment letter to the Food and Drug Administration (FDA) expressing reservations about the classification of ultra-processed foods (UPFs). This communication emphasizes the complexity and ambiguity surrounding the existing definitions and potential implications for public health policy.
The letter outlines that the NOVA classification system, which has been widely used to categorize foods based on processing levels, has led to confusion among both
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WASHINGTON, Nov. 25 -- The American Institute of Food Industry and Agricultural Biotechnology (ALAIAB), San Jose, Costa Rica, has submitted a public comment letter to the Food and Drug Administration (FDA) expressing reservations about the classification of ultra-processed foods (UPFs). This communication emphasizes the complexity and ambiguity surrounding the existing definitions and potential implications for public health policy.
The letter outlines that the NOVA classification system, which has been widely used to categorize foods based on processing levels, has led to confusion among bothconsumers and nutrition experts. ALAIAB argues that the system lacks clear criteria and measurable parameters, which raises challenges when identifying ultra-processed foods and assessing their health impacts. Citing scientific reviews from various countries, the organization points out that current evidence linking UPF consumption to health outcomes remains inconclusive and requires further research.
ALAIAB calls for a more balanced, evidence-based approach towards defining and regulating UPFs. The organization underlines that nutrient composition should take precedence over the degree of processing when evaluating the healthfulness of food items. This perspective aligns with the World Health Organization's principles for healthy diets, which emphasize the importance of nutritional adequacy, balance, moderation, and variety.
Moreover, the letter discusses the role of food additives, particularly their regulatory oversight which ensures that only those proven to be safe are permitted in food products. ALAIAB explains that excessive focus on the quantity of additives may not provide a comprehensive understanding of a product's safety or quality.
In highlighting the impact of palatability and energy density, the letter also references studies demonstrating that UPFs can sometimes be beneficial, potentially contributing to adequate nutrient intake when consumed in moderation. Furthermore, the organization urges the FDA to consider how reformulation efforts can improve the nutritional profiles of ultra-processed products rather than stigmatizing processed foods entirely.
ALAIAB's letter culminates in a call for consumer education initiatives to promote better understanding of nutrition labels and encourage balanced dietary choices that include a variety of foods-including those that are processed. The organization insists that a comprehensive definition of UPFs should consider not only the level of processing but also the broader nutritional landscape and consumer perceptions, ensuring it aligns with contemporary dietary guidelines and scientific evidence.
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4858
