Food Labeling: Revision of the Nutrition and Supplement Facts Labels

The American Frozen Food Institute (AFFI), on behalf of its member companies, appreciates the opportunity to provide the U.S. Food and Drug Administration (FDA) with comments on the proposed extension of the compliance date for the final rules on the Revision of the Nutrition and Supplement Facts Labels and Serving Sizes of Foods That Can Reasonably by Consumed at One Eating Occasion (NFL rules). As the voice of the U.S. frozen food industry, AFFI is the national trade association that promotes and represents the interests of all segments of the frozen food industry. AFFI fosters industry development and growth, and advocates on behalf of the industry before legislative and regulatory entities. AFFI supports NFL label reform as we recognize the importance of providing consumers with accurate, relevant nutrition information, critical for making informed shopping decisions. Our members are committed to implementing the final revisions to the NFL as outlined in FDA's recent final rule. However, the industry faces several obstacles in implementing these complex, time-consuming, and costly changes with limited vendor capacity to complete the volume of labeling by the original compliance date. More detailed comments in the attachment.

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the Food and Drug Administration's (FDA) supplemental proposed rule on Food Labeling: Revision of the Nutrition and Supplement Facts Labels. 1/ As the voice of the U.S. frozen food industry, AFFI is the national trade association that represents the interests of all segments of the frozen food industry. AFFI members manufacture and distribute frozen foods throughout the United States and globally. AFFI represents a broad group of companies that will be subject to the final rule. AFFI recognizes the importance of modernizing the Nutrition Facts Panel (NFP) to reflect current science and consumption data, and commends FDA for its leadership in updating these requirements. The agency's focus on conducting consumer testing is also welcomed. We are particularly appreciative that FDA has published for public comment the consumer research on the added sugars declaration and the percent Daily Value (DV) footnote, as well as the underlying raw data for these studies. We also appreciate that FDA has published for comment its consumer studies on the proposed NFP format revisions, which we are commenting on separately. As a general comment, AFFI believes the careful consideration of consumer research is essential to an effective final rule. To that end, AFFI strongly encourages the agency to critically review the consumer research - particularly the studies that show certain proposed changes would not meaningfully improve consumer understanding or would even result in consumer confusion - and reevaluate whether the costs of the proposal are justified by the benefits, including any benefits to consumer understanding. We would also encourage FDA to rely on not only its own consumer research, but to also consider research conducted by the International Food Information Council (IFIC) and other research submitted to the public docket. Please find our full comments attached.

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the Food and Drug Administration's (FDA) supplemental proposed rule on Food Labeling: Revision of the Nutrition and Supplement Facts Labels. 1/ As the voice of the U.S. frozen food industry, AFFI is the national trade association that represents the interests of all segments of the frozen food industry. AFFI members manufacture and distribute frozen foods throughout the United States and globally. AFFI represents a broad group of companies that will be subject to the final rule. AFFI recognizes the importance of modernizing the Nutrition Facts Panel (NFP) to reflect current science and consumption data, and commends FDA for its leadership in updating these requirements. The agency's focus on conducting consumer testing is also welcomed. We are particularly appreciative that FDA has published for public comment the consumer research on the added sugars declaration and the percent Daily Value (DV) footnote, as well as the underlying raw data for these studies. We also appreciate that FDA has published for comment its consumer studies on the proposed NFP format revisions, which we are commenting on separately. As a general comment, AFFI believes the careful consideration of consumer research is essential to an effective final rule. To that end, AFFI strongly encourages the agency to critically review the consumer research - particularly the studies that show certain proposed changes would not meaningfully improve consumer understanding or would even result in consumer confusion - and reevaluate whether the costs of the proposal are justified by the benefits, including any benefits to consumer understanding. We would also encourage FDA to rely on not only its own consumer research, but to also consider research conducted by the International Food Information Council (IFIC) and other research submitted to the public docket. Please find our full comments attached.

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the Food and Drug Administration's (FDA) supplemental proposed rule on Food Labeling: Revision of the Nutrition and Supplement Facts Labels. 1/ As the voice of the U.S. frozen food industry, AFFI is the national trade association that represents the interests of all segments of the frozen food industry. AFFI members manufacture and distribute frozen foods throughout the United States and globally. AFFI represents a broad group of companies that will be subject to the final rule. AFFI recognizes the importance of modernizing the Nutrition Facts Panel (NFP) to reflect current science and consumption data, and commends FDA for its leadership in updating these requirements. The agency's focus on conducting consumer testing is also welcomed. We are particularly appreciative that FDA has published for public comment the consumer research on the added sugars declaration and the percent Daily Value (DV) footnote, as well as the underlying raw data for these studies. We also appreciate that FDA has published for comment its consumer studies on the proposed NFP format revisions, which we are commenting on separately. As a general comment, AFFI believes the careful consideration of consumer research is essential to an effective final rule. To that end, AFFI strongly encourages the agency to critically review the consumer research - particularly the studies that show certain proposed changes would not meaningfully improve consumer understanding or would even result in consumer confusion - and reevaluate whether the costs of the proposal are justified by the benefits, including any benefits to consumer understanding. We would also encourage FDA to rely on not only its own consumer research, but to also consider research conducted by the International Food Information Council (IFIC) and other research submitted to the public docket. Please find our full comments attached.

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the Food and Drug Administrations (FDA) published consumer research related to the proposed rule on Food Labeling: Revision of the Nutrition and Supplement Facts Labels. / As the voice of the U.S. frozen food industry, AFFI is the national trade association that represents the interests of all segments of the frozen food industry. AFFI members manufacture and distribute frozen foods throughout the United States and globally. AFFI represents a broad group of companies that will be subject to the final rule. AFFI recognizes the importance of modernizing the Nutrition Facts Panel (NFP) to reflect current science and consumption data, and commends FDA for its leadership in updating these requirements. We are particularly appreciative that FDA has published for public comment the consumer research on the proposed new formats, as well as the underlying raw data for these studies. We also appreciate that FDA has conducted and published summaries of and raw data from its consumer research on added sugars and the percent Daily Value (DV) footnote, which we are commenting on separately. As a general comment, AFFI believes the careful consideration of consumer research is essential to an effective final rule. To that end, AFFI strongly encourages the agency to critically review the consumer research particularly the studies that show certain proposed changes would not meaningfully improve consumer understanding or would even result in consumer confusion and reevaluate whether the costs of the proposal are justified by the benefits, including any benefits to consumer understanding. We would also encourage FDA to rely on not only its own consumer research, but to also consider research conducted by the International Food Information Council (IFIC) and other research submitted to the public docket. Please find our full comments attached.

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the Food and Drug Administrations (FDA) published consumer research related to the proposed rule on Food Labeling: Revision of the Nutrition and Supplement Facts Labels. / As the voice of the U.S. frozen food industry, AFFI is the national trade association that represents the interests of all segments of the frozen food industry. AFFI members manufacture and distribute frozen foods throughout the United States and globally. AFFI represents a broad group of companies that will be subject to the final rule. AFFI recognizes the importance of modernizing the Nutrition Facts Panel (NFP) to reflect current science and consumption data, and commends FDA for its leadership in updating these requirements. We are particularly appreciative that FDA has published for public comment the consumer research on the proposed new formats, as well as the underlying raw data for these studies. We also appreciate that FDA has conducted and published summaries of and raw data from its consumer research on added sugars and the percent Daily Value (DV) footnote, which we are commenting on separately. As a general comment, AFFI believes the careful consideration of consumer research is essential to an effective final rule. To that end, AFFI strongly encourages the agency to critically review the consumer research particularly the studies that show certain proposed changes would not meaningfully improve consumer understanding or would even result in consumer confusion and reevaluate whether the costs of the proposal are justified by the benefits, including any benefits to consumer understanding. We would also encourage FDA to rely on not only its own consumer research, but to also consider research conducted by the International Food Information Council (IFIC) and other research submitted to the public docket. Please find our full comments attached.

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the Food and Drug Administrations (FDA) proposed rule on Food Labeling: Revision of the Nutrition and Supplement Facts Labels. As the voice of the U.S. frozen food industry, AFFI is the national trade association that represents the interests of all segments of the frozen food industry. AFFI members manufacture and distribute frozen foods throughout the United States and globally. AFFI represents a broad group of companies that will be subject to the final rule. We appreciate the opportunity to provide these comments and welcome a continuing dialogue with FDA on these important public health issues. Please refer to the attached document for AFFI's complete comments.

The American Frozen Food Institute (AFFI) requests an extension of the comment period for the Food Labeling: Revision of the Nutrition and Supplement Facts Labels Proposed Rule. Please see attached AFFI comments.