DOCSLIB.ORG

Guidelines for Ams Oversight of Commodity Research and Promotion Programs

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Guidelines for Ams Oversight of Commodity Research and Promotion Programs GUIDELINES FOR AMS OVERSIGHT OF COMMODITY RESEARCH AND PROMOTION PROGRAMS January 2020 Table of Contents I. Overview ..................................................................................................................................5 II. Budget Approval. .....................................................................................................................7 III. Donated Funds .........................................................................................................................8 IV. Contracts ..................................................................................................................................8 A. Contract Provision Requirements ......................................................................................9 B. Contract Justification........................................................................................................10 C. Contract Approval. ...........................................................................................................11 D. Contract Compliance........................................................................................................11 E. Subcontractors ..................................................................................................................11 F. Multi-Year Contracts. .......................................................................................................12 G. CEO Contracts .................................................................................................................12 H. Outside Legal Counsel Contracts .....................................................................................13 V. Finance, Compliance, and Program Accountability ..............................................................13 A. Financial Statements/Reports ...........................................................................................13 B. Refund/Reimbursement Requirements ............................................................................13 C. Activities and Expenditures .............................................................................................13 D. Annual Financial Audits ..................................................................................................14 E. Management Reviews ......................................................................................................14 F. Independent Evaluation ....................................................................................................15 G. Travel Expense Claims ....................................................................................................16 H. Credit Card Use ................................................................................................................17 VI. Refunds ..................................................................................................................................18 VII. Influencing Legislation and/or Government Policy ...............................................................19 VIII. Referendum Activities ...........................................................................................................20 IX. Policy on Review and Approval of Promotional and Educational Materials ........................21 X. Policy on Brand Names .........................................................................................................21 XI. Administration .......................................................................................................................21 A. Legal Counsel ..................................................................................................................21 B. Investment of Funds .........................................................................................................21 C. Bylaws, Policy Statements, Annual Reports, and Transparency .....................................22 D. Notice of Board Meetings ................................................................................................22 E. Board Administrative Expenses .......................................................................................22 F. Prohibited Expenditures....................................................................................................23 1. Spouse/Family Expenses ..................................................................................... 24 2. Open Bars............................................................................................................. 24 3. Influencing government policy or action ..............................................................24 4. Use of Funds for Personal Expenses .....................................................................24 5. Other Expenditures listed in this guidance document...........................................24 G. Goodwill Board Donations ..............................................................................................24 H. Compliance ......................................................................................................................25 I. Charging Research and Promotion Boards ........................................................................26 1. Direct Program Costs ........................................................................................... 26 2. Overhead .............................................................................................................. 26 3. Other Costs........................................................................................................... 26 J. Nominations for Board Membership .................................................................................27 K. Ethics ................................................................................................................................28 L. Civil Rights and Equal Opportunity .................................................................................29 M. Other Government Agencies ...........................................................................................30 N. Unemployment Practices. ................................................................................................31 O. Records Retention ............................................................................................................31 Appendix 1 – Authorizing Legislation Appendix 2 – Statement of Principle for Research and Promotion Boards and Marketing Orders for Information Sharing with Government Officials Appendix 3 – Directive 2210.2 “Investment of Public Funds” (2/7/11) Appendix 4 – Directive 420.3 “Debt Management” (5/10/04) Appendix 5 – List of Research and Promotion Boards Appendix 6 – Requirements for Outside Counsel Legal Services Contracts Appendix 7 – Marketing Communication Guidelines for Program Advertising, Promotional Material, Research, Social Media, and Other Publications United States Department of Agriculture Agricultural Marketing Service GUIDELINES FOR AMS OVERSIGHT OF COMMODITY RESEARCH AND PROMOTION PROGRAMS I. Overview Congress delegated to the Department of Agriculture (USDA) the responsibility for implementation and oversight of commodity promotion, research, and consumer information programs established under freestanding legislation, commonly known as “checkoff” programs. In 1996, the Commodity Promotion, Research, and Information Act, commonly known as the “Generic Act” was enacted to allow commodity groups to create programs for their commodities under a generic statute. Prior to the Generic Act, many of today’s programs overseen by USDA’s Agricultural Marketing Service (AMS) were established under commodity specific legislation (see Appendix 1). The Secretary has delegated all functions to AMS for these programs except those delegated to USDA’s Foreign Agricultural Service (FAS), which has been given the authority to oversee international marketing activities (Federal Register Vol. 62 No. 144). The funding for such programs is industry specific, usually through deductions from sales by producers, marketers, and/or importers, and the programs are directed by industry boards. However, the Federal legislation which provides the authority for the collection and expenditure of funds also mandates for all of the programs that the Secretary of Agriculture appoint the board members and approve the boards’ budgets, plans, projects, and contracts. USDA is committed to oversight of research and promotion (R&P) boards in ways that allow them to grow and adapt to a fast-changing marketplace, including leadership to serve on the boards that reflects a diversity of perspectives and opinions. The boards’ staff and appointed membership determine the direction of and carry out board programs and manage the boards. Every R&P program has a mission to maintain and expand the markets for its commodity. The boards are composed primarily of those in the marketing chain who pay assessments and as board members they decide how board funds are spent. Because these R&P programs use assessment money to carry out their functions, Page 5 transparency and oversight of these funds is critical. AMS’ role is one of oversight – to ensure compliance with all applicable legislation, regulations, and policies. State and regional promotion programs that have been authorized by Federal or State laws fall under those jurisdictions and as such those laws are controlling for those programs. Many of the State programs fall under the oversight of
Load more

Recommended publications
  • KASHRUS ALERTS September 22, 2019  a Service of the COR of Greater Detroit
    KASHRUS ALERTS September 22, 2019 A Service of the COR of Greater Detroit [Page 1] HONEY: • Standard honey goes through a filtering process, which removes the non-Kosher bee parts. Even “raw and unfiltered” honey is usually strained, to remove the bee parts. However, some completely unprocessed honeys are neither filtered nor strained. If the label or the manufacturer states that the honey is not strained, or if bee parts are visible, that honey should be avoided or should be strained by the consumer. • Please be aware that “ Forest honey”, “ Honeydew honey”, and “ Beechwood honey” (or honey named after other types of trees such as Pine, Fir, Oak, etc.), generally refer to honey produced by bees that have consumed the non-Kosher excretions of aphids and scale insects left on trees (as opposed to standard honey produced from flower nectar). These are not considered Kosher according to some opinions, and should be avoided. • “Royal Jelly” is a bee product that, unlike regular honey, is an actual secretion of the bee. Some Poskim therefore rule that it is not included in the permitted category of “honey”, and it should be avoided. FISH HEADS: [From New Square Kashrus Council] • White fish: White fish heads are free of infestation concern. • Salmon/Baby salmon: Salmon heads [even farm raised] are commonly infested with salmon lice (small brownish parasites ranging in size from approximately 1-3 cm). · The entire gills must be removed. (It may be easier to first cut the head in half before cleaning). · Rinse the head thoroughly with water while rubbing all surfaces of the head (inside and outside), including all cracks, crevices and folds, and under and around the tongue.
    [Show full text]
  • 5781 / 2021 Edition
    5781 / 2021 EDITION 1 - COPYRIGHT © 2021 BY VAAD HARABONIM OF QUEENS All Rights Reserved. The VHQ will once again have a community Kashering day –this Sunday, March 14th starting at 11am. Young Israel of Queens Valley 141-55 77th Ave 2 - WWW.QUEENSVAAD.ORG 141-49 73rd. Ave. Flushing, NY 11367 · (718) 520-9060 · Fax (718) 520-9063 Passover 2021/5781 DELEGATION OF POWER OF ATTORNEY FOR SALE OF CHOMETZ I, the undersigned (Name) Am the owner partner • other (Title) Of the following company: (Name of Company) Which has facilities in the following locations, where chometz may be stored: Store, Restaurant or Plant Name Street City State 1. 2. 3. 4. 5. I am authorized to appoint Rabbi Chaim Schwartz, or his appointed substitute to act as our legal agent for the transfer and sale of all chometz and chometz products in the possession of the company in any of the above locations, as well as any other location not listed. Included in this authorization is the right to rent any areas where any chometz may be found. The sale shall take place at the Rabbi's discretion beginning on the 12th day of the month of Nissan. Rabbi Schwartz is empowered to use any legal and halachic (Jewish law) procedures which he deems necessary to effect these transactions and for such duration as to conform to halachic requirements. This authorization is in conformity with all Torah and Rabbinic laws and with the laws of the State of New York and of the United States of America. By: Date: (Signature) 3 - PESACH (PASSOVER) 5781/ 2021 First Night Pesach, Saturday Night, 15 Nissan (March 27th) Candle Lighting……….
    [Show full text]
  • Quality. Service. Commitment to Excellence
    Quality. Service. Commitment to Excellence. www.gamweregood.com Since 1976 Our Philosophy and Mission The GAM Philosophy Since 1976, we have delivered high impact graphics, marketing messaging, advertisements, and print collateral at a fair price and with a quick turn. It’s no surprise, then, that we enjoy many long-term, mutually beneficial relationships with our customers. We are consistent, effective, and responsive. The GAM team is our greatest asset. We are committed to providing our highly-skilled staff with all the latest technology to produce the results customers deserve and expect, and a workplace that promotes professional growth and stimulates personal achievement. Community Involvement We are committed to contributing our time and talent to the communities we serve and supporting the organizations that assist the underserved in our area. Our heartfelt goal is to create a positive impact on our community, particularly for those in need. Giving back is not a chore. It is a privilege. Call us today to learn more about how GAM can make a positive difference in your business. 703.450.4121 Our History For the client already familiar with GAM Graphics and Marketing, it comes as no surprise when they see first-time customers become long-time clients. But where did the name come from, and who started what was to become a powerhouse, go-to company for creative, print and marketing needs? In the mid-1970s, Charles “Charlie” Grant founded Grace Christian Academy in Sterling, Virginia. Not withstanding his determination to give students a well-rounded, Christian- based education, Charlie wanted his young charges to graduate with marketable job skills.
    [Show full text]
  • Playing Chicken: Avoiding Arsenic in Your Meat Around the World Through Research and Education, Science and Technology, and Advocacy
    Playing Chicken Avoiding Arsenic in Your Meat Institute for Agriculture and Trade Policy Food and Health Program The Institute for Agriculture and Trade Policy About this publication promotes resilient family farms, rural communities and ecosystems Playing Chicken: Avoiding Arsenic in Your Meat around the world through research and education, science and technology, and advocacy. Written by David Wallinga, M.D. 2105 First Avenue South We would like to thank Ted Schettler, M.D., Minneapolis, Minnesota 55404 USA Karen Florini and Mardi Mellon for their helpful comments Tel.: (612) 870-0453 on this manuscript. We would especially like to acknowledge Fax: (612) 870-4846 the major contributions of Alise Cappel. We would like [email protected] iatp.org to thank the Quixote Foundation for their support of this work. iatp.org/foodandhealth Published April 2006 © 2006 IATP. All rights reserved. Table of contents Executive summary . 5 I. The modern American chicken: Arsenic use in context . 11 II. Concerns with adding arsenic routinely to chicken feed . 14 II. What we found: Arsenic in chicken meat . 21 Appendix A. FDA-approved feed additives containing arsenic . 26 Appendix B. Testing methodology . 29 References . 31 Playing Chicken: Avoiding Arsenic in Your Meat 3 4 Institute for Agriculture and Trade Policy Executive summary Arsenic causes cancer even at the low levels currently feed additive, are given each year to chickens. Arsenic found in our environment. Arsenic also contributes to other is an element—it doesn’t degrade or disappear. Arsenic diseases, including heart disease, diabetes and declines subsequently contaminates much of the 26-55 billion pounds in intellectual function, the evidence suggests.
    [Show full text]
  • Western Grocer Celebrates 100 Years!
    D E C N 6 1 U 0 2 O E N N U J / N Y A A M S T S I L A N I F — ™ S D R A W A T C U D O R P W E N X I R P D N A R G 5 1 0 2 E H T + RETURN UNDELIVERED TO MERCURY PUBLICATIONS LTD., 1313 BORDER STREUNIT 16, WINNIPEG MB R3H 0X4 CPM SALES AGREEMENT #40062509 AND JUST LIKE THAT, BREAKFAST BECOMES Everyday solutions A POWER BREAKFAST. the whole family will love. 9 powerful grams of plant9 - based protein Nothing beats a handful a day f0or heart health Honey Nut CheeriosTM Source of 15 essential has no artificial colours vitamins15 and nutrients or flavours, so The most preferred all you get is n u t1 i n C a n a d a the very best to start your day! © General Mills 1 1 10:00 AM Serving Western Canadians for 100 Years publisher’s perspective MAY/JUNE 2016 • VOLUME 102, NO.2 Western Grocer Celebrates 100 Years! In this Issue 1916 was a heady year in Western Canada with the First World War in full swing and the region’s 29 economy bursting at the seams, especially the 11 The 2016 SIAL Canada and SET 21 grocery industry where Winnipeg had already established itself as the supply Canada in Montreal centre for all of the West. That year the Winnipeg and Western Grocer Back in Montreal for its 13th edition, the SIAL International magazine put out its first issue.
    [Show full text]
  • Kosher Australia Pesach Guide
    Serving the Jewish Community since 1968 GUIDE FOR PESACH & PESACH PRODUCTS 2021 / 5781 as at 7/3/21 81 Balaclava Road, Caulfield North 3161 AUSTRALIA T: +61 (3) 8317 2500, 1300KOSHER (within Australia) W: www.kosher.org.au © 2021 Kosher Australia Pty Ltd Not to be reproduced without permission. Information not to be reproduced without acknowledgement. RABBINIC ADMINISTRATOR: Rabbi Mordechai Gutnick, AM ADVISORY BOARD: Rabbi Danny Mirvis, Rabbi Yonason Johnson, Rabbi Menachem Sabbach BOARD OF MANAGEMENT Mr Stephen Shnider, Llb, Chairman ADMINISTRATION Mr Yankel Wajsbort, B.Sc, C.P.I.M., General Manager Mr Mordi Joseph, B.Bkp, Operations Manager Mr Naftoli Biber, Audit Admin Ms Nechama Ruschinek, Admin Ms Dina Rosenbaum, Admin Mr Eli Paneth, Accounts INVESTIGATIONS Rabbi Kasriel Oliver B.App.Sc., M.R.A.C.I., C.Chem, Chief Chemist Mrs Rose Mehlman B.Sc, Mr Mordechai Hoenders M.Sc, Mr Adam Ruschinek, B.App.Sc Rabbi Yossi Herbst Mr Pesachya Adelist FIELD SUPERVISION Rabbi Arieh Berlin, Rabbi Benjamin Kessly, Rabbi Menachem Sabbach, Rabbi Benyomin Serebryanski, Rabbi Shraga Telsner ACKNOWLEDGEMENTS: We are grateful for the assistance of the following in preparing this Guide: Chicago Rabbinical Council, Illinois USA Kof-K, New Jersey USA, London Beth Din, London UK Orthodox Union, New York USA Rabbi A. Adler, Gateshead UK Rabbi G. Bess, Kollel America, Los Angeles USA Star-K, Baltimore USA The Kashrut Authority of NSW, Australia Rabbi YM Levinger, Switzerland Rabbi Danny Moore, BIR, England 1 TABLE OF CONTENTS USING THIS GUIDE .......................................................................................................... 6 PESACH CALENDAR - MARCH 2021 – NISSAN 5781 ......................................................... 6 FOOD OUTLETS IN MELBOURNE ..................................................................................... 7 GENERAL WARNINGS ....................................................................................................
    [Show full text]
  • Chemical Circularity in Fashion
    Chemical Circularity in Fashion BY PHIL PATTERSON, COLOUR CONNECTIONS CONSULTANCY LTD Chemical Circularity in Fashion STUDY COMMISSIONED BY ACKNOWLEDGEMENTS The author would like to thank the following for their input and constructive comments during the creation of this report. By thanking them here, full agreement with all the conclusions that have been drawn in the report on the subject of chemical circularity is not implied. Laudes Foundation is an independent foundation here to advance the transition to a just and regenerative Peter Gregory – Consultant economy. We do this by supporting brave action that John Murphy – Consultant will inspire and challenge industry to harness its power for good. Action that inspires industry, to work Nick Farrar – Nike collaboratively to create solutions and tools. And action Thomas Shafer – Bluesign that challenges industry, holding it to account and Linda Greer – IPE incentivizing change. John Mowbray – MCL News and Media Founded in 2020, Laudes Foundation is part of the Brenninkmeijer family enterprise and builds on six generations of entrepreneurship and philanthropy. In particular, we advance the industry-changing work of C&A Foundation. Learning from these experiences, we to work persistently and collaboratively to influence capital and transform industry, starting with the built environment and fashion industries. Laudes Foundation. Redefining value for the good of all. May 2020 Report by Phil Patterson, Colour Connections Consultancy Ltd Contents 1. Report Summary 2. Introduction and Purpose of the Report 3. Industry Background Information 4. Current Chemical Use – and opportunities for reduced use, increased recycling and leasing 5. Current Business Models 6. Making Non-linear Use Models Happen a.
    [Show full text]
  • A Niche Marketing Guide for Lamb Cooperatives
    ~ ~ United States ~ ..~ Department of G Agriculture A Niche Marketing Rural Business and Cooperative Development Lam~~_ Service Guide for ~TV c~~ ~'!!'ll,'~'E!""O- ~\ Research Report 142 Cooperatives \1. DOce .::,,' " II 8k~ 12 1996 I I'r.PAUl b P(;bAlJA-4- ············.\ Abstract The two types of niche markets targeted by lamb marketing cooperatives are described in this 1 guide. The first type includes specialty middlemen outlets that cooperatives used to market !, lamb to specialized niches within the traditional meat marketing system of retail food stores, restaurants, food service outlets, and specialty distributors. The second type includes those out­ lets that cooperatives used to market lamb directly to the consumer, such as freezer markets, farmers' markets, mobile markets, and mail order sales. This guide also describes the advertis­ ing, promotional, and other marketing programs used by cooperatives to target these markets. Finally the competition, product differentiation, capital requirements, market development, man­ agement, processing, changing goals, and member commitment challenges faced by these cooperatives are briefly discussed. Key Words: Cooperatives, lamb, niche marketing, marketing programs A Niche Marketing Guide for Lamb Cooperatives Tamra Kirkpatrick Kazmierczak and James B. Bell Department of Agricultural and Applied Economics Virginia Polytechnic Institute and State University Blacksburg, Virginia Research Report 142 OCtober 1995 Price: Domestic-$4.00; Foreign-$4.50 Preface Low market prices for lamb caused many producers to look for alternative market outlets. Between 1989 and 1993, at least 12 producer groups explored the possibility of forming lamb marketing cooperatives to target niche market outlets. Niche marketing differed from traditional lamb marketing because it targeted market outlets demanding unique product characteristics, packaging, and/or other convenience aspects not readily obtained through traditional suppliers of lamb such as auction buyers, order buyers, packer buyers, and commission sales representa­ tives.
    [Show full text]
  • Using Written Protocols to Guide Direct Procurement of Food from Sustainable Farmers, Producers
    Sustainable Farm-to-Hospital Toolkit Using Written Protocols to Guide Direct Procurement of Food From Sustainable Farmers, Producers WHY adopt A FARM-to- ■■ To mainstream hospital procurement of food directly Hospital sustainaBle Food from sustainable farmers/producers purcHasing protocol? ■■ To address the general food safety concerns that arise when serving both healthy and immune-compro- Hospitals are encouraged to adopt one or more farm- mised people to-hospital sustainable food sourcing protocols for the following reasons: ■■ To engender consumer confidence ■■ To assure hospital administrators and other inter- ested parties that the foods purchased directly from FiVE steps to deVeloping one or more sustainable farmers/producers came A purcHasing protocol from “approved sources” in compliance with volun- tary food service implementation of Hazard Analysis and Critical Control Points (HAACP) principles, Step 1 designed to reduce food safety risks1,2,3 Review the next section containing information on the impor- tant components of a purchasing protocol and the sample ■■ To provide sustainable farmers/producers with the protocols provided. Then, use the information provided to same information on hospital requirements and develop one or more draft protocols for the hospital. preferences and increase transparency ■■ To provide a simple, less onerous way to assure that Step 2 foods purchased directly from one or more sustain- Share the draft protocol with key food service staff, able farmers/producers are as safe, if not safer, than including but not limited to those involved in menu plan- similar foods purchased via a distributor ning, placing orders and supervising kitchen staff. Be sure to engage any staff member who has past experience in ■■ To formalize goals, procedures and requirements wholesale purchase of products from farmers/producers.
    [Show full text]
  • Healthy Green Living Media Archive: 1998-2012
    HEALTHY GREEN LIVING MEDIA ARCHIVE: 1998-2012 LIVING TOXIC FREE Sustainable living includes reducing the amount of toxic chemicals in your immediate environment. What we do Our Safer Solutions website has comprehensive information, easy guides and Q&As on home use, renovations and in the garden; as well as for child care centres. We believe in the right to know about pollution that affects our health and the environment. Total Environment Centre has been campaigning and providing credible information on toxic chemicals and safer alternatives and new laws to protect the community and the environment, for over two decades Latest News CREDIBLE GREEN LABELLING CRISIS • • Created on Wednesday, 05 December 2012 11:17 In an effort to stem consumer concern from a flood of ‘eco-labels’ and self-created green claims by product manufacturers in recent years, the Buying Better project released its proposals to improve the reliability of ‘green’ credentials today. The Buying Better project - undertaken by Green Capital, the business sustainability arm of the Total Environment Centre –investigated the green claims for 4 products: beef, cleaning products, small electronic goods and printing paper. ‘The findings show that a plethora of confusing and self-serving claims inevitably undermines consumer confidence as the “greening” of many product lines has attempted to move into the consumer mainstream,” said TEC executive director Jeff Angel. “Consuming products is not just about the private purchase contract, it’s about the effect of those decisions on society as a whole, and the health of the environment which sustains us all. So we have to get it right.” Mr Angel said the findings show that “Paper claims are almost chaotic; beef is just starting the sustainability journey, with early warnings of confusion; while small electronics needs government intervention.
    [Show full text]
  • <[email protected]> Sent: Monday, August 26, 2019 3:21 PM To
    From: John Osborne <[email protected]> Sent: Monday, August 26, 2019 3:21 PM To: Stoltz, Carrie R - DNR Cc: Bob Scarcelli ([email protected]) Subject: Response to July 25, 2019 Correspondence related to Rhinelander Municipal Well No. 7; BRRTS # 02-44-584094 Attachments: FINAL 20.0156342.00 Response to Request for Information_Rhinelander WI 8-26-19.pdf Greetings Carrie: In a letter dated July 25, 2019 you requested Charter NEX at 3606 Red Arrow Drive in Rhinelander, WI provide to the Wisconsin Department of Natural Resources information related to its operations in response to the detection of PFAS in Rhinelander Municipal Well No. 7. GZA GeoEnvironmental, Inc., (GZA) has worked with Charter NEX staff to compile and review relevant information and prepare the attached letter with supporting documentation for your review. Please feel free to reach out to me with any questions. We would appreciate you confirming receipt of this letter. Thank you, John John C. Osborne, P.G. Principal Hydrogeologist/ Senior Vice President GZA | 20900 Swenson Drive, Suite 150| Waukesha, WI 53186 Direct: 262-754-2590 | Cell: 262-424-2042 | [email protected] | www.gza.com GEOTECHNICAL | ENVIRONMENTAL | ECOLOGICAL | WATER | CONSTRUCTION MANAGEMENT Known for excellence. Built on trust. This electronic message is intended to be viewed only by the individual or entity to which it is addressed and may contain privileged and/or confidential information intended for the exclusive use of the addressee(s). If you are not the intended recipient, please be aware that any disclosure, printing, copying, distribution or use of this information is prohibited.
    [Show full text]
  • Staff Opinion Letter Addressing Compliance with the Decision And
    United States of America FEDERAL TRADE COMMISSION Washington, DC 20580 Division of Advertising Practices Bureau of Consumer Protection May 9, 2017 Mark S. Brown, Esq. King & Spalding LLP 1700 Pennsylvania Ave., NW Suite 200 Washington, DC 20006-47078 Re: Request for Informal Staff Guidance Regarding Santa Fe Natural Tobacco Company’s Consent Order (FTC Dkt. No. C-3952) Dear Mr. Brown: The Division of Advertising Practices has reviewed your letter submitted on behalf of RAI Services Company (“RAI”) and Santa Fe Natural Tobacco Company (“Santa Fe”), dated March 9, 2017, requesting informal staff guidance concerning the Federal Trade Commission’s consent order with Santa Fe (“Consent Order”).1 The consent order requires, among other things, a disclosure that “No additives in our tobacco does NOT mean a safer cigarette” in any cigarette advertisement that, through the use of phrases such as “no additives,” “no chemicals,” “additive free,” “chemical-free,” “chemical-additive free,” “100% tobacco,” “pure tobacco,” or substantially similar terms, represents that a tobacco product has no additives or chemicals (“cigarette disclosure”).2 This request for guidance was precipitated by a Memorandum of Understanding that RAI/Santa Fe entered into with the U.S. Food and Drug Administration’s (“FDA”) Center for Tobacco Products in January 2017. Under the Memorandum of Understanding, RAI/Santa Fe, agreed, among other things, to remove the phrase “Additive Free” and the term “natural” from 1 Your letter attaches the Santa Fe agreement, which was accepted for public comment on April 27, 2000. On June 16, 2000, the Commission made final that agreement and issued its Decision and Order (FTC Dkt.
    [Show full text]