As OMB considers opportunities for regulatory reform, FMI urges the agency to prioritize a critical evaluation of three rulemakings – the Food and Drug Administration’s (FDA’s) final rule on food traceability, FDA’s proposed rule on front-of-package nutrition labeling, and the Environmental Protection Agency’s (EPA’s) final rule on hydrofluorocarbon (HFC) management– each of which do or would impose costly, unnecessary, and unlawful burdens on the food industry without commensurate benefit to public health, the environment or food safety. As explained in more detail below, amending the food traceability rule, revising the HFC management final rule, and withdrawing the front-of-package nutrition labeling proposed rule, would alleviate unnecessary regulatory burdens, ensure that regulations are based on the best reading of the underlying statutory authority, and safeguard American businesses from regulations that impose costs that exceed anticipated public benefits.

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