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Export rule enforcement

This article was originally published in The Rose Sheet

Executive Summary

As it considers changes to the reg, FDA will continue to "exercise enforcement discretion" on requirement in its export notification and recordkeeping rule that records for exported cosmetics or foods be made available to the agency for inspection. Also suspended is mandate that marketers of all regulated products prepare a notarized certification that an exported product does not conflict with the laws of the importing country. Enforcement of two provisions earlier was postponed until July 19 in response to a joint request by CTFA and the Grocery Manufacturers of America (1"The Rose Sheet" July 1, 2002, p. 8). In a July 22 letter to the groups' outside counsel, Peter Barton Hutt (Covington & Burling), FDA said it may issue an advanced notice of proposed rulemaking to seek public comment...

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