Comment from International Food Additives Council (IFAC)
AnonymousOpposeTrade association
Summary: The International Food Additives Council (IFAC), a global trade association, opposes the broad removal of authorized solvents, arguing that the FDA should instead use a use-specific approach based on actual consumer exposure and manufacturing conditions. They emphasize that many current uses involve purification steps that minimize residues and warn that removing authorizations could lead to significant supply chain disruptions, increased costs, and technical feasibility issues.
The International Food Additives Council (IFAC) appreciates the opportunity to submit these comments in response to FDA's reopening of the food additive petition concerning certain solvents used in the manufacture of food additives (Docket No. FDA-2023-F-5684).
IFAC's comments provide information regarding current manufacturing practices, technical feasibility of alternatives, supply chain and ingredient availability considerations, and the importance of evaluating authorized uses based on actual exposure, conditions of use, and current scientific information.
IFAC appreciates FDA's consideration of these comments.