Submission Number: 07882
Received: 7/14/2011 4:48:00 PM
Commenter: Curtis Landherr
Organization: CSM Bakery Supplies North America
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
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Dear Chairman Leibowitz,
On behalf of the CSM group of companies in the U.S. (CSM is a leading business-to-business supplier of bakery products and ingredients worldwide and a leading player in natural food preservation and green chemicals), I am writing to join our industry colleagues in the Grocery Manufacturers of America (GMA) and other industry organizations to express our concern and opposition to the Preliminary Proposed Nutrition Principles to Food Marketed to Children by the Interagency Working Group (IWG), and strongly urge the withdrawal of these marketing restrictions.
We join our industry colleagues in feeling that these marketing restrictions represent a concerning regulatory overreach on the part of the IWG. As we understand it, the 2009 Omnibus Appropriations Act directed the FTC, USDA, FDA, and CDC to complete a study and provide recommendations to Congress. Instead, our understanding is that the IWG has proposed marketing restrictions of many healthy foods, including most soups, cereals, breads, and cheese. Worse still, we understand that the IWG’s standards are more restrictive than the standards for foods sold under the school lunch program, the WIC program, and even contradict the Administration’s own food recommendations to Americans.
We join others in our industry in urging the IWG to withdraw its proposed food marketing restrictions.
VP, General Counsel of CSM Bakery Supplies North America