The Lacuna Project

lacuna (n.) a gap in a record where something should be

Independent research. Not affiliated with any government, agency, or company.

Professional body

Consumer Brands Association

Findings that rest on exhibits naming this entity

  • AGR-1.11: FDA's proposed rule of 11 August 2026 would require GRAS notices for substances purported to be GRAS, with a one-year streamlined submission for substances already on the market. The rule creates no premarket approval, lets companies market a substance before notifying and while FDA reviews the notice, and makes failure to notify "a factor" in FDA's prioritization for post-market review.
  • AGR-1.14: California's AB 1264 (approved 8 October 2025) defines ultraprocessed food for school food by reference to a substance in FDA's Substances Added to Food database with one of eight listed technical effects, plus a nutrient threshold or a listed sweetener. On 11 February 2026 a federal court enjoined enforcement of Texas SB 25's warning-label requirement against four trade associations, including the Consumer Brands Association, and their members.

Exhibits naming this entity

  • Exhibit 573 August 2026 (file named GRAS_Onesheet_081326). Consumer Brands Association: Let's Mow Down the GRAS Myths (one-page fact sheet)
  • Exhibit 580 11 February 2026. U.S. District Court, Western District of Texas (Waco Division): American Beverage Association et al. v. Paxton, No. 6:25-cv-00566 (W.D. Tex.), order on motion for preliminary injunction