Comment from North American Millers' Association

The North American Millers' Association is providing the attached comments in response to the citizen petition submitted by David Kessler. NAMA represents millers of wheat, corn, oats, and rye. Our members take raw grain and, through grinding and crushing, create flour and other products that are used to make favorite foods, such as bread, cereals, pasta, tortillas, cookies, cakes, and snack foods. We’re proud to be the indispensable link between raw grain and healthy and delicious products that have sustained and enriched people’s lives for centuries. NAMA is very concerned about the broad implications of the petition. Revoking the GRAS status of flour and other common food ingredients would result in the arbitrary and unnecessary removal from the marketplace of safe, nutritious, and delicious grain foods that Americans have relied on for generations. The scientific consensus does not support this approach. Most refined grain foods are fortified with essential vitamins and minerals. They serve as important sources of critical nutrients, especially for pregnant women and children. Further, enriched and fortified refined grain foods are key sources of dietary fiber. Categorizing grain foods as “ultra-processed” and restricting them from diets could have a negative impact on public health by making it harder for people to get nutrients they are already under-consuming. The full text of NAMA's comments and references is attached.