FDA Public Meeting: Horizontal Approaches to Food Standards of Identity Modernization

Hogan Lovells
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On September 27, 2019 the U.S. Food and Drug Administration (FDA) hosted a public meeting to gather information from stakeholders on changes the agency could make to existing standards of identity (SOIs), particularly changes that could be made across categories of standardized foods (i.e., “horizontal” changes), to provide flexibility for the development of healthier foods and facilitate innovation. Though FDA primarily was in listening mode during the meeting, comments by agency representatives suggested FDA’s commitment to SOI modernization. In particular, the agency encouraged stakeholder comments to the docket, indicating interest in highly-detailed proposals for establishing horizontal approaches to SOIs that eliminate barriers to improvements in product nutrition profiles, spur innovation, and provide flexibility to allow emerging technology to reach consumers while ensuring sufficient transparency. Written comments are due by November 12, 2019, and can be submitted to FDA docket number FDA-2018-N-2381-1371. This memorandum provides a high-level summary of the agency statements and stakeholder comments made during the meeting.

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