Article
FDA’s Proposed GRAS Rule: Mandatory Notifications, Expanded Scope, And Open Questions
The FDA has proposed a rule that would fundamentally transform how food substances enter the U.S. market under the Generally Recognized as Safe (GRAS) framework, converting what has been a voluntary notification system into a mandatory disclosure requirement. Companies would be required to notify FDA of their GRAS conclusions before or shortly after introducing substances into interstate commerce, though the rule stops short of creating a premarket approval system. The proposal raises critical questions abo
Kelley Drye & Warren LLP