Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, rm. 1061
Rockville, MD 20852
December 4, 2009
RE: Docket ID FDA-2009-D-0430
Dear Ms. June,
Thank you for the opportunity to comment on this proposed guidance.
The Organic Trade Association is the membership-based business association for organic agriculture and products in North America. Its members include growers, shippers, processors, certifiers, farmers' associations, distributors, importers, exporters, consultants, retailers and others. OTA’s Board of Directors is democratically elected by its members. OTA's mission is to promote and protect the growth of organic trade to benefit the environment, farmers, the public and the economy (www.ota.com).
Many of our members use evaporated cane juice in their products, and have done so for many years. It is our understanding that there have been about 3,500 products (stock keeping units or SKUs) that have used this term since 1996. OTA receives calls from cosumers, and to our knowledge has never had any consumer questions about evaporated cane juice. Further, we find it unlikely that consumers would consider any “evaporated juice” to be a liquid juice.
OTA therefore recommends maintaining the status quo and requests that FDA withdraw this proposed guidance.
Thank you very much for your consideration.