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:
- Franck's Lab Court Case
- Interagency Working Group on Food Marketed to Children
- Executive Order 13563 — Improving Regulation and Regulatory Review
Source
"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.
