Exhibit 573

Let's Mow Down the GRAS Myths (one-page fact sheet)

Exhibit 573 · Trade association statement

Let's Mow Down the GRAS Myths (one-page fact sheet)

GRAS is not a loophole; it’s a science-based regulatory pathway established by Congress and overseen by the FDA.

Industry trade group's response to the August 2026 proposal. It supports mandatory notification as part of 'a national uniform standard,' says GRAS ingredients must meet the same 'reasonable certainty of no harm' standard as approved additives, and rejects the 'loophole' description.

Source: Consumer Brands Association
Date: August 2026 (file named GRAS_Onesheet_081326)
Quoted from: 'GRAS Is Just a Loophole' row
Grade: Primary record
Document: https://consumerbrandsassociation.org/wp-content/uploads/2026/08/GRAS_Onesheet_081326.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The document carries no date; the date is inferred from the file name. Second quote: 'The CPG industry has consistently supported greater transparency and welcomes GRAS reform as part of a national uniform standard for ingredient safety and transparency, including updated FDA regulations that require mandatory notification.' (first paragraph).

Cited by

Finding AGR-1.11: Primary record FDA's proposed rule of 11 August 2026 would require GRAS notices for substances purported to be GRAS, with a one-year streamlined submission for substances already on the market. The rule creates no premarket approval, lets companies market a substance before notifying and while FDA reviews the notice, and makes failure to notify "a factor" in FDA's prioritization for post-market review.