American Alliance for Biomanufacturing (AAB)
AdvocacySupport
Trait-based regulatory framework
Modified Organisms Subject to the Plant Protection Act
USDA-2026-0133-0001RFI
Comments
2,478
Last activity Jun 30, 2026
Deadline
Closed on Jul 1, 2026
Closed Jul 1, 2026
Net supportiSupport minus oppose · campaigns included
+14%
-49% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- Modified Organisms Subject to the Plant Protection Act
- Posted
- May 15, 2026
- Comment period
- May 15, 2026 – Jul 1, 2026
- FR Doc
- 2026-09833
- CFR
- 7 CFR Parts 330 and 340
- Topics
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Stance breakdown
+14%
Net support
Support1,402Oppose1,048Other28
Aggregates include form-letter campaigns. Excluding them, net support is -49% across organic comments.
Who commented
Breakdown by commenter type.
Academic
7
Business
16
Individual
2,159
Trade association
12
Advocacy
19
Other
265
Comments over time
Weekly arrivals, stacked by stance.
Posted May 15, 2026Deadline Jul 1, 2026
May 11May 25Jun 8Jun 22Jun 29
Support1,402Oppose1,048Other27
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Individual
63%
36%
1%
Other
0%
100%
0%
Advocacy
74%
21%
5%
Business
100%
0%
0%
Trade association
67%
8%
25%
Academic
100%
0%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Gmo safety and health1,333
Herbicide drift impacts1,295
Public notice and transparency1,081
Trait-based regulatory framework290
Post-approval monitoring270
Secure rule reinstatement15
Agrobacterium research regulation11
Liability and insurance11
Product-over-process regulation5
Cumulative environmental impact4
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | Trait-based regulatory framework | Secure rule reinstatement | Gmo safety and health | Agrobacterium research regulation | Product-over-process regulation |
|---|---|---|---|---|---|
American Alliance for Biomanufacturing (AAB) AdvocacySupport The American Alliance for Biomanufacturing (AAB), a coalition of biomanufacturing industry leaders, supports the USDA's | · | · | · | · | |
American Seed Trade Association Trade associationSupport The American Seed Trade Association (ASTA) supports the USDA's efforts to modernize the regulatory framework for genetic | · | · | · | · | |
American Society of Plant Biologists; ASM; Weed Science Society of America AdvocacyOppose The American Society of Plant Biologists (ASPB), the American Society of Microbiology (ASM), and the Weed Science Societ | · | · | · | · | |
Battelle Memorial Institute, Pacific Northwest Division BusinessSupport Battelle Memorial Institute, which operates the Pacific Northwest National Laboratory, argues that the current regulator | · | · | · | · | |
Bayer Crop Science BusinessSupport Bayer Crop Science supports the USDA's efforts to evaluate risk-based deregulation of genetically engineered (GE) organi | · | · | · | · | |
BPIA AdvocacySupport The Biological Products Industry Alliance (BPIA), representing over 180 member companies, supports the USDA's request fo | · | · | |||
Center for Food Safety AdvocacySupport The Center for Food Safety (CFS) argues that APHIS should move away from "genetic materiality" as a basis for regulation | · | · | · | · | |
CoverCress Inc BusinessSupport CoverCress Inc., an agricultural technology company, supports the USDA's evaluation of the regulatory framework for modi | · | · | · | · | |
Enzyme Technical Association Trade associationSupport The Enzyme Technical Association (ETA), a trade association representing enzyme manufacturers and marketers, supports th | · | · | · | · | · |
GMO/Toxin Free USA AdvocacyOppose GMO/Toxin Free USA, a public interest nonprofit, opposes shifting the regulation of genetically engineered (GE) organism | · | · | · | ||
Information Technology & Innovation Foundation AdvocacySupport The Information Technology and Innovation Foundation (ITIF) argues that the existing regulatory regime for genetically e | · | · | · | · | |
InnerPlant, Inc. BusinessSupport InnerPlant, Inc., an agricultural biotechnology startup, supports a science-based, risk-proportionate regulatory framewo | · | · | · | ||
International Alliance for Phytobiomes Research AdvocacySupport The International Alliance for Phytobiomes Research, a non-profit consortium, argues that there are no inherent material | · | · | · | ||
Microbial Biotechnology Policy Committee AdvocacySupport The Microbial Biotechnology Policy Committee (MBPC), a task force of companies developing microbial products, supports A | · | · | · | · | |
National Grain and Feed Association Trade associationSupport The National Grain and Feed Association (NGFA) supports the USDA's role in regulating modified organisms under the Plant | · | · | · | · | · |
Pluton Biosciences, Inc. BusinessSupport Pluton Biosciences, Inc., an agricultural biotechnology company, supports the development of a more rational, risk-propo | · | · | · | ||
Precision Fermentation Alliance AdvocacySupport The Precision Fermentation Alliance (PFA) supports the USDA's effort to modernize the regulatory framework for modified | · | · | · | · | |
Simplot Plant Sciences BusinessSupport The Simplot Company, an agribusiness, supports a shift toward a risk-based, product-focused regulatory framework for mod | · | · | · | · | |
Society for In Vitro Biology AdvocacySupport The Society for Society In Vitro Biology (SIVB) argues that the USDA should discontinue the distinction between conventi | · | · | |||
The Agriculture Biotechnology Alliance AdvocacySupport The Agriculture Biotechnology Alliance (ABA), representing producers and biotechnology developers, supports the USDA's i | · | · | · | ||
The Breakthrough Institute AdvocacySupport The Breakthrough Institute supports streamlining the regulation of agricultural biotechnology by moving toward a risk-pr | · | · | · | ||
The International Food Additives Council (IFAC) Trade associationSupport The International Food Additives Council (IFAC), a trade association representing manufacturers of food ingredients, sup | · | · | · |
American Seed Trade Association
Trade associationSupport
Product-over-process regulation
American Society of Plant Biologists; ASM; Weed Science Society of America
AdvocacyOppose
Agrobacterium research regulation
Battelle Memorial Institute, Pacific Northwest Division
BusinessSupport
Trait-based regulatory framework
Bayer Crop Science
BusinessSupport
Secure rule reinstatement
BPIA
AdvocacySupport
Trait-based regulatory framework
Secure rule reinstatement
Product-over-process regulation
Center for Food Safety
AdvocacySupport
Trait-based regulatory framework
CoverCress Inc
BusinessSupport
Trait-based regulatory framework
Enzyme Technical Association
Trade associationSupport
GMO/Toxin Free USA
AdvocacyOppose
Secure rule reinstatement
Gmo safety and health
Information Technology & Innovation Foundation
AdvocacySupport
Trait-based regulatory framework
InnerPlant, Inc.
BusinessSupport
Trait-based regulatory framework
Secure rule reinstatement
International Alliance for Phytobiomes Research
AdvocacySupport
Trait-based regulatory framework
Gmo safety and health
Microbial Biotechnology Policy Committee
AdvocacySupport
Trait-based regulatory framework
National Grain and Feed Association
Trade associationSupport
Pluton Biosciences, Inc.
BusinessSupport
Trait-based regulatory framework
Gmo safety and health
Precision Fermentation Alliance
AdvocacySupport
Trait-based regulatory framework
Simplot Plant Sciences
BusinessSupport
Agrobacterium research regulation
Society for In Vitro Biology
AdvocacySupport
Trait-based regulatory framework
Secure rule reinstatement
Agrobacterium research regulation
The Agriculture Biotechnology Alliance
AdvocacySupport
Trait-based regulatory framework
Product-over-process regulation
The Breakthrough Institute
AdvocacySupport
Trait-based regulatory framework
Secure rule reinstatement
The International Food Additives Council (IFAC)
Trade associationSupport
Trait-based regulatory framework
Gmo safety and health
Form letters
Campaigns
Organized form-letter drives, separated from organic one-off comments.
43%of comments arrived through a form-letter campaign — 1,056 of 2,477 comments. 1,415 are organic, and 6 are still being processed for campaign detection.
Campaign1,056Organic1,415Not yet determined6
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
Filter:
- Jun 30, 2026BPIASupportAdvocacy📎 Attachment
The Biological Products Industry Alliance (BPIA), representing over 180 member companies, supports the USDA's request for information to modernize the regulatory framework for modified organisms. They argue for a science-based, risk-proportionate pathway that provides clear commercialization endpoints and reduces duplicative oversight for microbial products.
Read comment → - Jun 30, 2026The Agriculture Biotechnology AllianceSupportAdvocacy📎 Attachment
The Agriculture Biotechnology Alliance (ABA), representing producers and biotechnology developers, supports the USDA's interest in modernizing and deregulating the oversight of modified organisms. They argue for a risk-proportionate, science-based regulatory framework that focuses on the product rather than the process to ensure American farmers remain competitive and have access to innovative biological solutions.
Read comment → - Jun 30, 2026American Seed Trade AssociationSupportTrade association📎 Attachment
The American Seed Trade Association (ASTA) supports the USDA's efforts to modernize the regulatory framework for genetically engineered (GE) organisms to make it more risk-proportionate and science-based. They advocate for redefining "regulated articles" to focus on actual plant pest risks rather than the development process, while also requesting the restoration of specific exemptions and streamlined processes from the SECURE Rule.
Read comment → - Jun 30, 2026Dorothy BrooksSupportIndividual
The commenter criticizes the USDA for a lack of transparency in the public comment process but ultimately supports the proposed action of moving toward a paradigm of quick deregulation for organisms assessed to pose a low risk. They argue that this approach would restore common sense to biotechnology regulation and benefit both large and small developers.
Read comment → - Jun 30, 2026Steven StraussSupportAcademic📎 Attachment
Steven H. Strauss, a University Distinguished Professor at Oregon State University, supports a "red flag" regulatory system that focuses on direct, demonstrable plant pest risks rather than the methods used to create modified organisms. He argues for exempting non-coding sequences, native-like modifications, and disarmed Agrobacterium strains from regulation to reduce the burden on innovation and public sector research.
Read comment →