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Section 305 of the FDA Food Safety Modernization Act specifically calls for FDA to develop recommendations on whether and how to harmonize requirements under the Codex Alimentarius Commission (“Codex”), an international organization charged with developing food standards, guidelines, codes of practice and “other recommendations to ensure fair practices in food trade and protect[ion of] the health of consumers.” FDA’s International Food Safety Capacity-Building Plan is largely supportive and deferential to Codex, concluding that “the use of Codex standards helps assure a safe global food supply.” To be sure, Codex’s stated mission and policies should create and facilitate adoption of universal standards and best practices to ensure a safe global food supply, supported as it is by the World Health Organization and the Food and Agricultural Organization, specialized UN agencies with well-regarded research capacity. This paper challenges the FDA’s current approach to Codex standards. Using common criticisms of Codex — that it favors rich countries over poor, industry over consumers, and trade over health — it urges FDA to use its new authority to ensure that Codex standards are informed by advances in nutrition science, to bring greater transparency to Codex decision-making, and to integrate its overseas capabilities with its activities at Codex.



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