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Rules Without Rulemaking

March 28, 2012

Executive Summary

Jim Davidson, chair, public policy practice committee and managing partner, Polsinelli Shughart PC, and Mary Catherine Toker, vice president, government and public affairs, General Mills, Inc., discussed the attempt by the Interagency Working Group (IWG) in 2010 to revise the nutritional standards for foods and beverages advertised during children’s TV programs. The standards would have also restricted the marketing of these products to anyone under the age of 18, impacting a large number of programs for adults. Although the danger posed by the IWG’s proposal has passed, many in the industry believe that the IWG’s actions were an indication of how federal agencies may attempt to circumvent their limited rulemaking authority in the future.

Related handouts:


"Rules Without Rulemaking." Jim Davidson, Chair, Public Policy Practice Committee and Managing Partner, Polsinelli Shughart PC; Mary Catherine Toker, Vice President, Government and Public Affairs, General Mills, Inc. ANA Advertising Law and Public Policy Conference, 03/28/12.