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AHPA comments on FDA post-market assessment prioritization tool

August 27, 2025
 
The American Herbal Products Association (AHPA) has submitted comments on a method proposed by the Food and Drug Administration to rank substances in food for post-market assessment. This proposed assessment tool scores food chemicals on a variety of criteria to determine which should be subject to further scientific and regulatory scrutiny. 
 
Among its comments, AHPA strongly objected to the inclusion of subjective, perception-based criteria (such as social media attention) in the proposed scoring system, which would compromise an objective evaluation of objective, scientific evidence and potentially misdirect limited public health resources. AHPA's comments further call for greater specificity and standardization of remaining scoring criteria that are related to public health information. In particular, AHPA noted that any evaluation of a given food chemical must consider its specific form, history of use, and exposure context.
 
"The proposed system would apply the same standards to unlawful pesticide residues and staple crops", said Robert Marriott, AHPA Vice President for Government and Regulatory Affairs. "...and As proposed, these standards are critically underdeveloped. AHPA encourages a more detailed approach that narrows its focus to intentional food substances."
 
AHPA will continue to monitor, advise, and report on shifts in FDA approaches to the surveillance and evaluation of ingredients already in the marketplace.

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