Anonymous - Comment

Document ID: FDA-2009-N-0025-0006
Document Type: Public Submission
Agency: Food And Drug Administration
Received Date: February 18 2010, at 12:25 PM Eastern Standard Time
Date Posted: February 18 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: November 23 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: February 22 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80aa78d1
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There is significant information available on the importance of complete and detailed information that is displayed on food labels, and this proposed regulation would go far in helping consumers to make informed purchasing decisions for their pets as they do for themselves. Color additives, the red coloring in particular can cause allergic reactions, which may be severe in our pets, leading to expensive vet bills, or much worse. In addition, consumers have the right to know what they are bringing into the household, particularly those with small children, who may ingest this food, which makes this issue even more pertinent. From a business perspective, the additional cost for compliance with this regulation is minimal. There are no label redesign changes, only minor changes in wording on the ingredient list. In addition, many pet food manufacturers are already compliant with these new regulations because the FDA had provided informal education to manufacturers in the 1990s in anticipation of the impending changes under NLEA. As a result, an informal 2007 survey of 68 pet food and specialty pet food labels found only 13 to be questionably compliant and only one definitely out of compliance with the proposed rule. Also, the FDA is allowing animal food manufacturers 2 years to deplete their current label inventories as they make the change to the new labels. It is in the best interest of the manufacturers to have the new labels available for retail sale as soon as possible in order to be ahead of their competitors. The reason for this is that many consumers may purchase the brands that clearly state the ingredients, including the color additives, over those that don’t; many consumers may be willing to switch to an alternative product.

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