Comment from National Cotton Council of America

Summary: The National Cotton Council, representing the U.S. cotton industry, argues that APHIS should adopt a risk-based, trait-focused regulatory framework rather than one based on the method of development (e.g., genetic engineering). They advocate for moving toward a revised 7 CFR part 330 to ensure that regulations are proportionate to actual plant pest risks, which would reduce burdens on smaller entities and improve international trade competitiveness.