The FDA's Decision on MoCRRA

The FDA is changing the place where companies can submit their ingredient list to the FDA for review. My sense based on the notices from the FDA and also having the opportunity to sit in on a call with the FDA is that they're still sorting through how they're going to implement their obligations and responsibilities under MoCRRA. Companies can look at what has been surmised, which is there's going to be more transparency,. More information required around ingredients; consistent record keeping. I think it's a time where a brand owner and a contract manufacturer should go and say, all right, let's assume the most stringent requirements or worst case scenario.