Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
Featured Stories
Indiana Soybean Alliance Raises Concerns Over Ultra-Processed Food Classification
Carter Struck
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
... Show Full Article
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.
***
The letter was signed by:
Courtney Kingery | CEO
Indiana Soybean Alliance
*
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
Carter Struck
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
... Show Full Article
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.
***
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
*
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
Carter Struck
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
... Show Full Article
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.
***
The letter was signed by:
Brittany Green
Executive Director
brittany@flpeanuts.com
*
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
Carter Struck
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
... Show Full Article
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.
***
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
Carter Struck
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
... Show Full Article
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.
***
The letter was signed by:
William C. Frantz
Executive Director
Cranberry Institute
www.cranberryinstitute.org
*
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
... Show Full Article
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.
***
The letter was signed by:
Kimberly Houlding
President and CEO
American Olive Oil Producers Association
*
Suzanne Moreau
Executive Director
California Olive Oil Council
*
Todd Sanders
Executive Director
Olive Oil Commission of California
*
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
... Show Full Article
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.
***
Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4858
