.- ‘. I DEPARTMEF OF HEALTH 81 HUMAN SERVICES Public Health Service \ Food and Drug Administration __ Washington DC 20204 Paula M. Nothofer Regulatory Compliance-Labeling Kraft Foods, Inc. 555 South Broadway Tarrytown, New York 10591 Dear Ms. Nothofer: This is to acknowledge your letter of January2,200 1, to the Food and Drug Administration (FDA), accepting the agency’s invitation to participate in the extended temporary market testing of “white chocolate” that was granted to Hersey Foods Corporation (59 FR 67302, December29 1994). Previously, in a letter dated September25, 1995, FDA granted a permit to Kraft Foods to participate in the extended temporary market testing of white chocolate under Docket No. 93P-0310. That permit allowed for the market testing of a product named “Premium White Chocolate Baking Squares.” The permit was amendedon August 23, 1996, to provide for an additional total of 30,391 kilograms (67,000 pounds) of other white chocolate products. The agency is granting a further amendmentto the permit of September25,1995. The amendment will allow for the market test of anotherproduct that contains white chocolate. The product will bear the name “Baker’s Brand Premium White Chocolate Chunks.” The white chocolate component of the product differs from the standardizedchocolate products in that it is preparedwithout the nonfat components of the ground cacaonibs, but contains the fat (cocoa butter) expressedfrom the ground cacaonibs. In all other respects,the white chocolate component would conform to the cacaoproduct standards. Relying on the representationsmade in your application, we are hereby granting permission to make interstate shipments,for market testing purposesof 88,000 pounds (39,909 kg) of new test product. The product will be manufactured at Barry Callebaut USA, Inc., 400 Industrial Park Road, St. Albans, VT 05478-1875 and will be distributed throughout the United States. The draft label that you submitted for the test food is acceptablefor the purpose of this market test. A finished label must be submitted to the Director, Division of Standards and Labeling Regulations, Office of Nutritional Products, Labeling and Dietary Supplements(HFS-820), before the product is shipped in interstate commerce. Each of the ingredients used in the food must be declared on the label as required by the applicable sections of 2 1 CFR Part 101. While this permit is in effect, FDA will refrain from recommending regulatory action. against shipments of “Baker’s Brand Premium White Chocolate Chunks” coveredby this Page 2 - Ms. Paula M. Nothofer permit on the grounds that the food fails to comply with the standardsof identity for certain chocolate products, e.g., chocolate liquor (2 1 CFR 163.11l), sweet chocolate (21 CFR 163.123),milk chocolate (21 CFR 163.130), buttermilk chocolate (21 CFR 163.135), skim milk chocolate (2 1 CFR 163.140), or mixed dairy product chocolates (21 CFR 163.145). Christine . ewis, Ph.D. Director v Office of Nutritional Products, Labeling and Dietary Supplements Center for Food Safety and Applied Nutrition ANDREA M.BRUCE DIRECTDIAL ATTORNEY AT LAW (202)6374X6 HOGAN& HARTSONL.L.P. 555THrRIEENM%TGET,b4%' WASHINC~ON,DC~OOO~ TEL.(202)637-5600 FAX (202) 637-5910 AMBRUCE@HHLAW.COM January2,200l LorettaA. Carey FoodStandards Branch(HFS-158) and Divisionof Programs Enforcement Policy Officeof Food Labeling Centerfor FoodSafetyandAppliedNutrition Foodand DrugAdministration 200 C Street,S.W. D.C. Washington, 20204 Re: Docket Numbers 93P-0310,94P-OU7 21 CFR 130.17(i)-Notice of Participation In Extended Market Test Of White Chocolate DearMs. Carey: that On July 20,1995,we notifiedthe Foodand DrugAdministration KraftFoods,Inc. to in acceptsthe agency’sinvitation participate the extended markettestof whitechocolate, in on announced the FederalRegister December 29,1994;59 Fed.Reg.67302(DocketNo. 93P- the product, 0310). At this time,we are notifying agencythat Kraftintendsto includean additional Bakers BrandPremiumWhiteChocolate Chunks,in the ongoingmarkettest 57 DocketNo. 94-P-01 (JulyI, 1994;59 Fed.Reg.33976) the docketnumberfor the temporary permitto marketwhitechocolate originallyissuedto Kraltin 1994,containsrelevant procedural of test historyas well as a description the proposed product The productdescription has not changed,but is repeatedherefor convenient reference. 1. is addressis Three Lakes The nameof the applicant KraftFoods,Inc. The headquarters IL Drive,Northfield, 60091. 2. in of and KraftFoodsis regularlyengaged the business manufacturing marketingcacao products. 3. we of The “whitechocolate” proposeto markettest differsfromthe existingstandards identityfor chocolate e.g., products, chocolate I), liquor(21 CFR163.11 sweetchocolate milk (21 (21 CFR63.123), chocolate CFR 163.130)buttermilk chocolate Kraft Foods 555 Soutll Broadway l Twrytown, NY 10591 1 LorettaA. Carey January2,200l Page2 (21 (21 CFR 163.135)skim milkchocolate CFR 163.140)and mixeddairyproduct (21 chocolates CFR163.145). 4. from of that The proposeddifference the existingstandards identityrecognizes the product and commonlyknownamongconsumers in othercountriesas ‘white chocolate“ made is with cocoabutter. The cocoabutteris producedby filteringgroundcocoanibsto remove the darkcocoasolids. of we The composition the “whitechocolate” proposeto markettest is consistent thewith in standardof identityfor Whitechocolate’proposed citizen’spetitionsfiled by Hershey and FoodsCorporation the Chocolate Manufacturers (Docketnumbers Association and 86-PO2971CP2 86P-02971CP3). the we Morespecifically, “whitechocolate” proposeto markettest is the solidor semi- plasticfood preparedby intimatelymixingand grindingcocoabutterwith oneor more nutritivecarbohydrate and sweeteners one or moreof the optionaldairy ingredients specifiedin 21 CFRpart 163. The productcontainsnot lessthan 20 percentcocoabutter, not lessthan 14 percenttotal milk solids,not lessthan 3.5 percentmilk fat, and not more than 55 percentnutritivecarbohydrate sweetener.It containsno coloringmaterial,but may containemulsifying agents,spices,naturaland artificialflavoringandother and seasonings, antioxidants for approved food use. 5. is and as The food “whitechocolate” just as wholesome non-deleterious the cacao or productsthat aresubjectto existingstandards identity. No novelingredients of are of processes usedin the production “whitechocolate”. 6. for and and The existingstandards sweetchocolate milk chocolate, for theotherchocolate for productscited above,includeminimumrequirements the additionof chocolate liquor, whichcontainsgroundcacaonibs. ‘Whitechocolate” containsthe cacaofat from ground solidsfoundin chocolateliquor. cacaonibs,but notthe darkchocolate 7. The purposeof effectingthe proposed variationis to facilitatethe markettestingof ‘white of chocolate”in the UnitedStates,underthe statement identitythat is in commonuse in the othercountriesandis mostinformative the consumer.Additionally, markettest will to of facilitatethe collection dataon consumer of acceptance the productto support the petitionsfor a standardof identityfor “whitechocolate” alreadyon file withthe Foodand as DrugAdministration, citedabove. cc A soundlegal casecan be madethat no permitor newstandardis neededto authorize the in almostcertainlyis an sale of “whitechocolate” this country. Indeed,“whitechocolate” appropriately statement identity,independent the existingstandards. descriptive of of LorettaA. Carey January2,200l Page3 we the Nevertheless, acknowledge Agency’sapparent for preference the useof the in temporarymarketingpermitprocess this case. Forthat reason,we arefilingthis notification. 8. wouldbenefitconsumers makingit easyfor them The variationfrom existingstandards by real to distinguish &hite chocolate” products from productsmadewith cheapercacaofat the of substitutes.Additionally, removal darkcocoasolidsfrom the chocolate formula resultsin a uniquemilkywhitecolorand a strongmilkyflavorthat seemsto be preferred by manyconsumers. 9. - Chunksthat The labelfor the Baker’sBrandPremiumBakingChocolate WhiteChocolate Kraftplansto addto the ongoingmarkettest is attached. IO. on Duringthe markettest we expectto distribute an annualbasis88,000Lb. of Baker’s 12oz. Premiumwhitechocolate chunks. 11. throughout UnitedStates. The productwill be distributed the 12. by The productwill be manufactured Ban-y CallebautUSA,inc., 400 IndustrialParkRoad, St Albans,VT 05478-1875.Thetelephone I. numberfor this facilityis (802)524-971 At and this time,the plantmanageris ChrisDemambro the QualityManageris Stuart Redfield. or at Pleasedo not hesitateto contactme at 914-335-6548 in my absence,SherryMarcouiller 847- if 646-4206, you needadditional information.Thankyou for yourcooperation. submitted, Respectfully KraftFoods,Inc. PaulaM. Nothofer Compliance Labeling Regulatory - cc: SherylA. Marcouiller SeniorFoodand DrugCounsel Attachment .. I. HoGAN&HARTSON 7 yp-u L.L.F! Writer’s Direct Dial: COLUMBIA SQUARE 202-636-6466 555 THIRTEENTH STREET, NW a WASHINGTON, DC 200941109 TEL (202) cm-5600 February 2,200l FAX (202) 637-5910 WWW.HiBAW.COM BY HAND DELIVERY Loretta A. Carey Food Standards Branch (HFS-158) Division of Programs and Enforcement .Policy Office of Food Labeling Center for Food Safety and Applied Nutrition Food and Drug Administration 200 C Street, S.W. Washington, DC 20204 Re: Baker’s Brand Premium White Chocolate Chunks - Notice of Participation in Extended Market Test of White Chocolate Dear Ms. Carey: As a follow-up to our conversation earlier today, I am providing some additional information with regard to the above-referenced notice of participation for Baker’s Brand Premium White Chocolate Chunks, submitted by Kraft Foods, Inc. @raft) on January 2,200l. First, I have enclosed a copy of the revised label for the product. As we discussed, it bears the words “Distributed by” fully spelled out on the information panel. Second, I understand that you will be talking with CFSAN colleagues about the appropriateness of using the abbreviation “Dist.” in place of the words “Distributed by”. To facilitate your discussions, I thought it might be helpful to share some information as to why Kraft believes this abbreviation is fully consistent with FDA regulations and policy. w Specifically, I have attached a copy of Section 201.1(h) of the agency’s drug labeling rules, and the corresponding preamble discussion. These documents reflect a determination by the agency to permit abbreviations of the phrases used to ? identify a product’s packer or distributor so long as those abbreviations are cle.ar and unambiguous. Because no consumer reasonably could misconstrue the letters BRUSEL§ LONDON PARIS’ EXJDAPEST PRAGUE* WARSAW MOSCOW TORY0 -. \\\DC.60685/4 -#126059$vl NEWYORK BALTlhfOBE McLBAN bIIAMI DENVER BOULLtER COLORADOSPRINGS UISANGEIXS HOGAN & HAIUSONL.L.P Loretta A. Carey February 2,200l Page 2 “Dist.” as indicating that Kraft is the product’s manufacturer (rather than distributor), Kraft is confident that this abbreviation meets that standard. As you can see from the attached correspondence, USDA reached the same conclusion many years ago with regard to the labeling of meat products. Section 101.5 - the pertinent regulation with regard to the labeling of foods - is fully consistent with Section 2Ol.l(h)‘s allowance for abbreviations. Although the phrase “Distributed by” is spelled out in that regulation, it is offered only as an example of the phrases that meet the regulatory requirement. When Kraft submitted its notice of participation for Baker’s Brand Premium White Chocolate Chunks last month, it had every reason to believe that CFSAN would follow the logic reflected in the agency’s drug labeling rules. The policy objectives of Sections 201.1(h) and 101.5 are, after all, identical, namely to identify for regulators and consumers the entity responsible for a product in the event of problems or concerns. CFSAN’s sudden objection to the “Dist.” abbreviation - which Kraft has used for many years on a wide variety of food products - simply was not and could not have been anticipated. As the enclosed label demonstrates, Kraft has proceeded to revise the label for Baker’s Brand Premium White Chocolate Chunks to spell out the words “Distributed by”. An inventory of labels bearing the abbreviation “Dist.“, however, does exist. I look forward to speaking with you and your colleagues about those labels, as well as the status of the notice of participation for Baker’s Brand Premium White Chocolate Chunks on Monday, February 5. Andrea M. Bruce ’ Enclosures cc: Sheryl A. Marcouiller, Esq. . . \\\DC-6068514 -#126059’7vl ‘9201.1 21 CFR Ch. I (4-l-00 Edliion) Food and Dnig ~dmWtmtlon, HHS (2) If the person performs at least one used in this paragraph, person, when it (4) If a trademark appears on the (m) This section does not apply to bi- applicable operation listed in para- identifies a corporation, includes a par- drug or drug product label or appears ological drug products that axe subject graph (b) of this section and identifies ent, subsidiary, or affiliate company as a mark directly on the drug product to the requirements of section 361 of by appropriate designation all other where the related companies are under (e.g., tablet or capsule), the label may the Public Health Service Act, 42 persons who .have performed the re- common ownership and control. identify the holder or licensee of the U.S.C. 262. maining applicable operations, e.g., (f) The name of the person rep- trademark. The label may also state Apr. 15, 1990; FR 72118, Oct. 145 FR 95’775, 45 “Made by (Person A), Filled by (Person resented as manufacturer under para- whether the person identified holds the 31, 1980, as amended at 48 FR 37620. Aug. 19, B), Sterilized by (Person C)“; or graph (b) or (c) of this section must be trademark or is licensee of the trade- 19931 (3) If the person performs at least one the same as either (1) the name of the . mark. applicable operation listed in para- establishment (as defined in $207.3(b)of (5) If the distributor is named on the #zOlS and devices; National graph (b) of this section and the person this chapter) under which that person label. the name shall be aualified by Drug 3 C e number~3. is listed along with all other persons is registered at the time the labeled one of the following phraeea: “Manu- The National Drug Code (NDC) num- who have performed the remaining ap- product is produced or (2) the reg- factured for ‘* “Distributed ber is requested but not required to ap- plicable operations as “joint manufac- istered establishment name of a par- ,, “Man;factured by pear on all drug labels and in all drug turers.” A list of joint manufacturers ent, subsidiary, or affiliate company by $9 “Manu- for ’ , labeling, including the label of any pre- shall be qualified by the phrase “Joint- where the related companies are under factured for 1, scription drug container furnished to a ly Manufactured By " and common ownership and control. In ad- byB, - \ 6”Distributor: , “Marketed consumer. If the ND0 number is shown the names of all of the manufacturers dition, the name shall meet the re- 3%. qualifging phrases The on a drug label, it shall be displayed as shall be printed together in the same quirements of paragraph (g) of this sec- by \ may be abbreviated. required in !j26735(b)(3) of this chapter. type size and style; or tion. (4) If the person performs all applica- (g) The requirement for declaration (6) If the packer is identified on the 140 FR 52902, Nov. 7.19751 ble operations listed in paragraph (b) of of the name of the manufacturer, pack- label, the name shall be qualified by this section except for those operations er, or distributor shall be deemed to be the phrase “Packed by 9’ or #201.6 Drugq adequate directiona for listed in paragraph (d) of this section. satisfied, in the case of a corporate per- “Packaged by *‘. The quali- use. For purposes of this paragraph, person, son, only by the actual corporate fsing phrases may be abbreviated. Adequate directions for use means di- when it identifies a corporation, in- name, except that the corporate name (i) The statement of the place of busi- rections under which the layman can cludes a parent, subsidiary, or affiliate may be the name of a parent, sub- ness shall include the street address, use a drug safely and for the purposes company where the related companies sidiary, or affiliate company where the city, State, and ZIP Code. For a foreign for which it is intended. (Section are under common ownership and con- related companies are under common manufacturer, the statement of the 261.l26 defines “intended use.“) Direc- trol. ownership and control. The corporate place of business shall include the tions for use may be inadequate be- (d) The Food and Drug Administra- name may be preceded or followed by street address, city, country, and any cause, among other reasons, of omis- tion finds that it is the common prac- the name of the particular division of applicable mailing code. The street ad- sion, in whole or in part, or incorrect tice in the drug industry to contract the corporation. LICompany.” “Incor- dress may be omitted if it is shown in specification of: out the performance of certain manu- porated” etc., may be abbreviated or a current city directory or telephone (a) Statements of all conditione, pur- facturing operations listed in para- omitted and “The” may be omitted. In direotorg. The requirement for inolu- poses, or uses for which such drug is in- graph (b) of this section. These oper- the case of an individual, partnership, sion of the ZIP Code shall apply to con- tended, including conditions, purposes, ations include: (1) Soft-gelatin encap- or association, the name under which sumer commodity labels developed or or uses for which it is prescribed, rec- sulating, (2) aerosol filling, (3) steri- the business is conducted shall be used. revised after July 1.1969. In the case of ommended, or suggested in its oral, lizing by irradiation, (4) lyophilizing, (h)(l) Except as provided in this sec- nonconsumer packages, the ZIP Code written, printed, or graphic adver- and (6) ethylene oxide sterilization. tion, no person other than the manu- shall appear either on the label or the tising, and conditions, purposes, or (e) A person performs an operation facturer, packer, or distributor may be labeling (including the invoice). uses for which the drug is commonly listed in paragraph (b) of this section identifled on the label of a drug or drug (j) If a person manufactures, packs, used; except that such statements shall only if the operation is performed, in- product. or distrfbutes a drug or drug product at not refer to conditions, uses. or pur- cluding the performance o&he appro- (2) The appearance on a drug product a place other than the person’s prin- poses for which the drug can be safely ‘prlate in-process quality control oper- label of a person’s name without quali- cipal place of business, the label may used only under the supervision of a ations, except laboratory testing of fication is a representation that the state the principal place of business in practitioner licensed by law and for samples taken during processing, as named person is the sole manufacturer lieu of the actual place where such which it is advertised solely to such follows: of the product. That representation is drug or drug product -was manufactured practitioner. (1) By individuals, a majority of false and misleading, and the drug or packed or is to be distributed, unless (b) Quantity of dose. including usual whom are employees of the person and, product is misbranded under section such statement would be misleading. quantities for each of the uses for throughout the performance of the op- 502(a) of the act, if the person is not (k) Paragraphs (b), (c), (d), (eh and (f) which it is intended and usual quan- eration, are ‘subject to the person’s di- the manufacturer of the product in ac- of this section. do not apply to the la- titiea for persons of different ages and rection and control; cordance with this seotion. beling of drug components. different physical conditions. (2) On premises that are continuously (3) If the names of two or more per- (1) A drug product is misbranded (c) Frequency of administration or owned or leased by the person and sub- sons appear on the label of a drug or under section 562(a) of the act if its la- application. ject to the person’s direction and con- drug product, the label may identify beling identifies a person as manufac- (d) Duration of administration or ap- trol; and which of the persons is to be contacted turer, packer, or distributor, and that plication. (3) On equipment that is continu- for further information about the prod- identification does not meet the re- (e) Time of administration or appli- ously owned or leased by the person. As uct. .quirements of this section. cation (in relation to time of meals, - .- Fedetal Register J Vol. 45, No. 74 / Tuesday, April 15. 1980 / Rules and Regulations 25769 r * %&&a~ to the Spedfketions of would not fully dlscloet the extent OF abbreviations is mMe&ing is itaeif t -“. ate any mote likely to mleleed a that pemon’econtribution. funds to invalidate the pmvisian cormuwn as to the identity of the Although thu agencyacognize8 the under Ahnay, hc v. Colifano, 568F.2d manufacturer than the phreScN, ’ veJuablacontribution that a product . 874,932 p.c. citw 1977). permitted by the tinatregulatioa the developer(or innovator) make@, and The agmcy agreesthat abb&viatlo . epncy believes that thesephrereo cm4 agreesthat Adistributor identification, of should be pennttted of thae phrauzs be mirleadiog in rugetrting that 8 : a developermey be Mmewhat that 0 ZO~.I@) ellowe in Identifying the product madeto one dirtributor’o inedequate.it believe, that to permft a diettibotot and PAdWt. Such . 6pedficatioar Ir eupetiar in quality to of devsIoperto be identified an ouchon the abbreviattolonn, course.should be clear quivplent products marketedby other product label would detract f&n the and unambiguoue./ . firms. As noted in the posedrule on prominenceand conspicuousness that Tmdemark ? 2herapeudwKyaquiv r ent drug must under rection ~ZO(C) the act be of moducte. “&ceot for identified and accordedword@ stat&tents that am 35.Several comment8noted that $oble& of bioiaequivalenca,FDA ie resuired to appearon the label 6 ZJJl,l(hJ (i ZOl.l(fl an propoeed)would not aware&at any therapeutically Q&ding atiiementa nquired to appear &nit the persoasidentified on the &g .igadGcantdufeteacur CuttentIy mint t under section602(b)(i] of the act). - pproductlabel to the menuf8ct~er, among ph4umaceuticaUy equivalent * Therefore.the agencyreject8these packet, or dielributor of the drug ptoducts whkh mdt from differenwe WfQUl8d8. product. The commentsurged that the .between public compendia1 (or 33.One wmment stated that . owner of a trademark who liceneesthe antibiotic1 rtandards end htier internal g xn.i(h? (8 zcn.l(r] ae pmpowd] ia .trademarkto another company should l tnndarde of manufactwers? FDA thue defident in that It allowo the . also be allowed to be identified on the bdievw that even when the written identification of the manufacturerwith label as the owner of the trademark The ipedficetiom for a product aremore the opdon to omit the name of ths commentsargued that iderdfiwtion of damanding than thoeeof genuiwlty padqer or di&ibutor who actually the licen~n, of the trademark on the qufvalent producte,the difference8in delivers the product hto interutete Mel ia regardedis good aademark l pedficatioos do not ordinatily produce wmmerce.The commentcontendedthat practice. One commentstated that a that . recent Canedten court decision a cKfference product queiity‘ Became U A manufacturer prwhcer a product for a trademarkowner may lore hisheld ia or ber the phrasesdted in the commenthave - reveral distributors who are not tights in the trademark if the liceused the ~tentiat to mislead comwmem to Identified on the product label+li, the b&eve that A uroduct msde to the event of a retail or mislabeling, It might product label does not rtete who owns epedfiwdons bf one,distributor la be impossibleto ascertain who was the trademark.The cdmmentclaimed superior to equivalent productr, the responsiblefor the product. tiat other countries follow the Canadian agency wncludea that thesepliraaes Thir commentinwrrectly eaumes practice. Finally, one comment should not be allowed. that the egeocybes the authority to e-ted that along with permitting the require the distributor or packer to be ldentificetion of the trademark licenser, si. One wmment askedfor Identified on the drug product label. No the proposal rhou!d permit the clntUicetlon of the provldon fn statutory pmvision gives the agency tdentificetiou 011 lube1 of the iicensee the ) zm.i(h) fQZ&I(~) a# proposed)which such aullqily. What is required under a8 a licenwe. states that “No parson except the the Federallaw ie that the drug product The qency did not intend to manufacturer, packer, or gliirtributor my the lnbel beer the ntxw of the manufacturer, &ompromise rightg of a trademark be identi5ed on the label of a drue or packer, ot diitributor. The choice of z bolder in itr trademark. Suction 2Cfl.l(h~ drug product”. !Z’he comment#tat& itu which of thesepemonr or which - has beenrevised to etete that both the- assumption that any one.or any combination of thesepersonaam to be licenaor and licensee of a trademark cqmbinatioa of tbwe three persons,may fdentifted is left to the labeler of the that eppeerr on the drag product or . appear on the label. The commentnoted mduct and to the mquirementr of State product label may he appropriately tbst olany stetyl ~ntl;vrequim . . E W. identi6ed on the dng product IabeL. identicalion on a w product label.of Even wltbut thu authority to requim both Qe manufactwr and distributor, if that e drug product label identify the .cdgas. ’: the product is di~trihuted by a person person who is diredly maponslblefor ~6.Sevemi Gents recommended other then the madechu+ bbrodudrg the pmduct Into interstate that proposed 62ul.s(g) be deleted.That The applicable rtatute (u&i@’ : C wmmeme, the agencybebe that m~ctibn Gould requireyif a person’~ w2(h)(i) of ihe act) and re@;txyn (y . ,&era am adequatemechaninun to . name mark, lmprlnt, or other identify@ .CFR ZOl.l), while determlnc who, in fact, war eo written, printed or graphic matter (Le.. -y$! identi6cation of the man actumr. .: nsponrible end thus to trace products product “logos appeareddirectly on the packer, or distclbutor, do not prohibit a that em iublect to a nxaU or to an drug pmduct that the label state fin0 horn identifying any lwo or all action to wmed a n&branding. 1 whether the person identified on the ~ofthesepemollsonthe8anl8~ ..,“‘. - - pmduct is the manufactumr, packer, ot distributor. One commentmed that the ptovision would diswura@ the use of logoaby personswho might not qualify au the manufacturer under thu terms of the regulation. Another commmt took issue with the stated - justification for the requirement.The commentnoted that the preamble juatifiea the proposedrequirement by stating that uw of 8 logo has the potential to mielead consumeraby - * leading consumersto baLievethat the SENT BY:M S THOMPSON P C ; 10- 5-89 2:2SPM ; 3124549636+ bl t’ 1.
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