Comment 5: Shen, Valerie

I applaud ATF’s mirror implementation of the FDA rule on cochineal extract and carmine to improve consumer safety. However, I believe both rules should go further and indicate the source of the dye, mainly that it is an animal product derived from an insect. The Center for Science in the Public Interest promoted this inclusion in the original FDA rule after their involvement in numerous adverse-reaction consumer reports. They rightly point out that many vegetarians, vegans, people of religious faiths (i.e. Jews and Muslims), and other groups who systematically rely on ingredients labels be interested in having this information. Most likely, industry groups involved in the production of cochineal extract and carmine would resist the inclusion of “insect” or “animal” product in labeling, for fear of driving off consumers who apart from vegetarians or people faith, may find the prospect of insect parts in their beverages unappetizing. This may be the case, but this intuitive risk is even more reason to allow consumers to be fully aware of what they are putting in their bodies. Freedom of information can only serve to enhance competition and make for better overall products. Furthermore, the cost of revamping the labels is low and admitted to not have “a substantial economic impact” by at least one industry interest, the International Association of Color Manufacturers in their public comment. It would be even more efficient to make the “insect” requirement at the same time of the general cochineal extract disclosure labeling requirement. There are already requests for extending the transition period, and if granted businesses should have more than a fair amount of time to implement this additional change as well. Thank you for the opportunity to comment.