No Such Thing as Simple Food Labeling: Changes Ahead in 2018

by Morgan Lewis

Morgan Lewis

Significant statutory and regulatory changes are on the horizon this year in the world of food labeling as regulators and lawmakers introduce rules that can potentially impact the food industry and its compliance obligations.

The US Department of Agriculture (USDA) is expected to release its long-awaited bioengineered (GMO) disclosure label rules in the next several days or weeks, which will establish a national standard for labeling foods containing GMO ingredients. Meanwhile, the US Food and Drug Administration (FDA) confirmed that it is pressing ahead with many label issues and initiatives, such as conducting a review to modernize standards of identity, ingredient statement requirements, and food label claims, such as creating a definition for the term “healthy” with a corresponding label symbol. Further, Congress has stepped into the conversation. Recently, the House of Representatives passed a bill called the “Common Sense Nutrition Disclosure Act”[1] to weaken menu label requirements for restaurants and retailers as was mandated by the Affordable Care Act.[2]

USDA Expected to Release GMO Disclosure Label Rules

The USDA is expected to release (most likely this month) rulemaking that implements a nationwide product labeling solution for food products containing GMO ingredients.

Congress passed and President Barack Obama signed into law the National Bioengineered Food Disclosure Law in the summer of 2016.[3] The statute gave USDA three options to consider for such a disclosure, including a written text, symbol, or electronic or digital disclosure method printed directly on a food label.[4] Based on recent comments by USDA Marketing and Regulatory Programs Under Secretary Greg Ibach at the Nebraska Governor’s Agriculture Conference in Kearney, Nebraska, it is likely the GMO disclosure will include either a symbol or some sort of electronic or digital disclosure method (e.g., a QR code consumers can scan for more information on the use of GMOs in food).

USDA has shown interest in providing unique pathways for consumers to utilize in order to conduct their own research as it relates to the use of GMOs by way of an electronic or digital disclosure. For example, USDA hired a consulting firm to conduct research related to whether an electronic or digital disclosure would be feasible and beneficial to consumers, given consumers would need access to certain types of technology to benefit from any electronic or digital disclosure method (e.g., smartphones and relevant applications). While the study outlined setbacks related to technical challenges using mobile software applications for scanning digital links, overall the study seemed to offer favorable results for the use of an electronic or digital disclosure.[5]

Given USDA has publically stated it does not want the GMO disclosure to come off as a “warning” to consumers, the electronic or digital disclosure may be the best solution for USDA to meet its statuary obligation for implementing the nationwide GMO disclosure law while not alarming consumers that there is any sort of safety issue in the use of GMOs in the food supply. While there are very heated debates pertaining to the safety of GMOs on both sides of the argument, USDA has made an effort to claim that this disclosure is not due to a public safety concern.

USDA is on track in meeting its statutory deadline to publish final rules on GMO label requirements by the July 2018 deadline. This is surprising, given USDA is considering many important questions in order to publish these final rules. For example, USDA must consider what the disclosure text, symbol, or electronic or digital disclosure code will say to inform consumers that a food product contains GMO ingredients. More complex questions include whether there should be an actionable threshold limit related to the amount of GMO ingredients present in a food item and also what “breeding techniques” would trigger the GMO disclosure requirement.[6]

As it relates to “breeding techniques,” USDA recently provided greater clarity as to what we can expect in the ultimate GMO disclosure rules. Specifically, USDA issued a statement on March 28 on plant breeding innovation, indicating that “USDA does not regulate or have any plans to regulate plants that could otherwise have been developed through traditional breeding techniques as long as they are not plant pests or developed using plant pests (emphasis added).”[7] This should be welcome news for those entities using new methods for plant breeding, such as genome editing.

USDA sent its proposed rules to the White House Office of Management and Budget (OMB) on December 27, 2017. It is expected these rules will be published in the next several days or weeks, with a 30-day comment period from the public. Current discussions among industry indicate USDA is likely to embrace a symbol or electronic or other digital disclosure method. Please follow our blog for the latest updates on the GMO labeling disclosure regulations, which we should be expecting very soon.

FDA Recognizes “Clean Label” Principles and Confirms Rulemaking for “Healthy” Term

FDA Commissioner Dr. Scott Gottlieb confirmed the agency plans to continue the Obama-era push to modernize food label claims by creating a definition for the term “healthy” with a corresponding labeling symbol.

This is the second time Dr. Gottlieb has shown a commitment to define the term “healthy” under a scientific framework that focuses less on nutrients and more on overall wholesome foods.[8] At the National Food Policy Conference (NFPC) held in Washington, DC on March 29, Dr. Gottlieb did not shy away again from unveiling that the agency is open and willing to conduct a complete overhaul on the use of the product claim “healthy.”[9] He suggested using a symbol or a standard icon or other symbol that represented the term “healthy.” He also said the criteria surrounding the use of this symbol would be based on current science in order to promote better consumer eating habits, including possibly expanding the term beyond just nutrient qualifications to better reflect food groups, such as “whole grains, low fat dairy, fruits and vegetables and healthy oils.”[10]

Redefining the requirements for the term “healthy” is not a new endeavor for FDA.[11] Currently, the agency codified requirements for the use of the term “healthy” in 21 CFR § 101.65(d)(2).[12] However, back in 2016, FDA issued a guidance document on stating that it would exercise enforcement discretion related to “healthy” claims that

  • are not low in total fat, but have a fat profile makeup of predominantly mono and polyunsaturated fats; or
  • contain at least ten percent of the Daily Value (DV) per reference amount customarily consumed (RACC) of potassium or vitamin D.[13]

The agency published this guidance document given FDA wanted to “re-evaluate the regulatory criteria for use of the implied nutrient content claim ‘healthy’ in light of the latest nutrition science and the current dietary recommendations and seek input on possible future rulemaking to update the existing regulations for this claim.”[14] Dr. Gottlieb confirmed the agency is pursuing rulemaking to update the definition of “healthy,” with plans to solicit stakeholder input in the near future.

FDA Recognizes the Importance of “Clean Label” Principles

During his NFPC speech, Dr. Gottlieb acknowledged current trends in diet and nutrition, stating that “consumers are seeking out foods that meet criteria like minimally processed, lower in sugar, and produced with wholesome ingredients.”[15] We have written and presented on the “clean label” movement and topics, which you can read more about here and here.

During his speech, Dr. Gottlieb announced his Nutrition Innovation Strategy, indicating that FDA intends to modernize its approach to food labeling in order to ensure consumers are more knowledgeable about the foods they eat and how food labels and labeling deliver this information to consumers. The Nutrition Innovation Strategy will include work to modernize (i) label claims, (ii) ingredient statements, (iii) standards of identity, (iv) health claims, and (v) sodium daily values. The commissioner also renewed the agency’s commitment to implement the new Nutrition Facts Panel and Serving Size final rule, whose compliance date has been extended to January 1, 2020, for manufacturers with $10 million or more in annual sales, and January 1, 2021, for manufacturers with $10 million or less in annual sales.[16]

Whether there will be much movement on these topics is subject to debate, given the agency’s current primary focus is on matters affecting immediate public health and consumer safety. However, Dr. Gottlieb’s recent comments at NFPC seem notable, as it suggests the agency is now willing to take on the arduous rulemaking tasks related to these topics with the start of public comments as soon as this summer. It should be noted that the commissioner also addressed defining the term “natural,” but offered no substantive update. Please follow our blog for the latest updates on the Nutrition Innovation Strategy agenda.

Congress Presses Ahead to Weaken Menu Labeling Laws, and Recognizes Internet Labeling as a Sole Method for Nutrition Disclosure

While FDA’s current menu labeling compliance date for restaurants and retailers is set for May 7, 2018, Congress is stepping in to upend some of the menu labeling requirements as mandated by the Affordable Care Act.

The House of Representatives recently passed the “Common Sense Nutrition Disclosure Act” to ease menu labeling rules for restaurants and retailers as required by the Affordable Care Act.[17] Notably, this is the first statutory recognition that we know of that contemplates allowing a food establishment who receives orders by consumers placed off-premises (such as a pizza restaurant) to disclose nutritional information solely on a remote access-menu, such as a website. The bill also eliminates criminal penalties and allows retailers to implement corrective actions before further enforcement actions. Importantly, the bill also preempts civil litigation for violations of the federal menu labeling law and any state laws that may exist.[18]

If enacted, this bill will no doubt make it easier for restaurants and retailers to comply with menu labeling laws by utilizing websites as a sole means for displaying nutrition information. However, it should be noted that many of these entities have already invested in on-premise displays to comply with FDA’s fast approaching menu labeling compliance deadline. For those entities that have yet to comply, the bill’s enactment will surely ease regulatory burdens. However, it is unlikely this will occur before FDA’s current May 8, 2018, compliance deadline. The House of Representative passed the bill on February 6, 2018, and it is now with the House Committee on Energy and Commerce: Subcommittee on Health. The bill has 86 cosponsors (80 Republicans and 6 Democrats).

It is unknown how the bill will impact FDA’s current menu labeling deadline. However, we know FDA has extended the menu labeling deadline in the past when Congress dealt with matters related to the Affordable Care Act. For example, FDA extended the previous menu labeling requirement enforcement deadline from May 5, 2017, to May 7, 2018, the same week the House of Representatives passed repeal of the Affordable Care Act. While repeal of the Affordable Care Act ultimately failed, it is an indication that FDA is willing to extend these deadlines in light of continued congressional action.

[1] Common Sense Nutrition Disclosure Act of 2017, HR 772, 115th Cong. (2017). You can track the progress of this bill here.

[2] The Patient Protection and Affordable Care Act, HR 3590, 111th Cong. (2010).

[3] The National Bioengineered Food Disclosure Standard, S 764, 114th Congress (2016) (enacted). A full text of the bill can be found here.

[4] You can find out more information about the GMO disclosure and labeling requirements from USDA here.

[5] You can read more about USDA’s study of electronic and digital disclosures here.

[6] You can read more about the questions USDA had to consider in promulgating the GMO disclosure rules here.

[7] You can find Agriculture Secretary Sonny Perdue’s statement on plant breeding innovation here.

[8] You can read Dr. Gottlieb’s October 15, 2017, interview with the Wall Street Journal here.

[9] You can read Dr. Gottlieb’s full speech to the NFPC here.

[10] Id.

[11] More information on FDA’s nonbinding recommendations related to “healthy” in labeling of human food can be found here.

[12] You can access the eCFR cite here.

[13] See “Guidance for Industry: Use of the Term “Healthy” in the Labeling of Human Food Products,” which you can access here.

[14] Id.

[15] Id.

[16] You can find out more information on Nutrition Facts Panel label compliance deadlines here.

[17] You can track the progress of this bill here.

[18] You can find out more information on the Common Sense Nutrition Disclosure Act here.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morgan Lewis | Attorney Advertising

Written by:

Morgan Lewis

Morgan Lewis on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.