Voluntary Disclosure of Sesame as an Allergen: Guidance for Industry; Availability; Agency Information Collection Activities; Proposed Collection; Comment Request,”

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the Food and Drug Administration's (FDA's) draft guidance on the voluntary declaration of sesame as an allergen. From manufacturers to distributors to suppliers to packagers, AFFI is proud to represent publicly traded and family-owned companies who help produce frozen foods and beverages for today's food service and retail marketplace and serve as economic pillars within their communities throughout the U.S. The frozen food industry contributes approximately $56 billion to U.S. GDP and accounts for 670,000 U.S. jobs. In addition to our members' strong role in economic growth, AFFI members share a commitment to transparently communicating information about the nutritional content and ingredients in the foods they produce and sell. Please refer to the attached document for AFFI's comments on FDA's legal authority to issue the draft guidance and procedural considerations under the Administrative Procedure Act; the importance of establishing a consistent scientific standard to assess food allergens; the limitations of the draft guidance with respect to the recommendation to identify sesame in the ingredient statement but not in the "Contains" statement; and the importance of international coordination with FDA's counterparts in Canada and Mexico.