Comment from World Alliance of Coffee Decaffeinators

Please accept the attached public comment opposing the petition as drafted. The petition asks FDA to remove authorizations for benzene, ethylene dichloride, methylene chloride, and trichloroethylene. FDA should not grant that request without a substance-by-substance and use-by-use record establishing current commercial use, meaningful consumer exposure, causal attribution, processing-aid status, and statutory applicability. The petition creates a misleading impression by treating old regulatory authorizations as if they prove current use in the food supply. That is not the known-use reality. For coffee decaffeination, the only current commercially relevant use among the four substances is methylene chloride. Benzene, ethylene dichloride, and trichloroethylene are not current coffee decaffeination solvents in modern commercial practice. For hops, current commercial extraction is centered on carbon dioxide extraction, not legacy chlorinated-solvent pathways. Methylene chloride decaffeination must be evaluated based on the actual process and actual exposure. Methylene chloride is used as a processing solvent to extract caffeine from green coffee beans. It is not added to coffee as an ingredient and has no function in the brewed beverage. The process is designed around removal and recovery through controlled extraction, solvent recovery, evaporation, stripping, drying, roasting, grinding, and brewing. A regulatory residue limit is not evidence of meaningful exposure in coffee as consumed. FDA should also reject any approach that treats detection as attribution. A detected chemical in food does not prove that the detected substance came from the challenged authorized use. FDA should require validated residue data, transparent sampling, and evidence that any residue is causally attributable to the relevant use and present in the food actually consumed. Voluntary process labeling already gives consumers choices, including Swiss Water, Water Processed, CO2 Process, and Naturally Decaffeinated products. Those labels may reflect process preference or premium positioning, but they do not prove that methylene chloride decaffeination is unsafe. FDA should not convert voluntary process marketing into mandatory warning-style disclosure unless it first establishes a material safety difference under actual conditions of use. FDA should deny the petition as drafted. If FDA proceeds further, it should do so only through a disciplined, use-specific record grounded in current commercial practice, actual consumer exposure, validated residue data, and the statutory text.