Submissions

On April 11, 2025, the U.S. Office of Management and Budget (OMB) issued a request for information for proposals to rescind or replace regulations that stifle American business and ingenuity. There are a significant number of FDA regulations that either stifle or are burdensome to the consumer healthcare industry.

These comments aim to address dietary supplement rules, regulations, guidance, or other federal policies that are inconsistent with statutory text or the Constitution, where costs exceed benefits, where regulations are outdated or unnecessary, or where regulations impose unforeseen burdens on American businesses.

PCPC and CHPA recommend the removal of over-the-counter drug products such as sunscreens and medicated topical creams and lotions as defined by the U.S. Food and Drug Administration (FDA) from the scope of this proposed regulation.

We applaud the intentions of the proposed rule to expand access to needed products for contraception. We note, however, that the proposed rule raises significant challenges that would need to be addressed.

CHPA members have been working diligently on assessing potential for nitrosamine formation from APIs used in OTC medicines.

CHPA supports well-tailored efforts to protect the sensitive personal data of U.S. persons, including efforts intended to protect and strengthen the national security of the United States.

CHPA supports FDA’s continued efforts to support medical device innovation by facilitating to the use of PCCPs for efficient Agency review of medical device modifications. When finalizing the Draft Guidance, CHPA strongly encourages FDA to provide further clarity regarding the content and process for PCCPs on several points.

CHPA supports the Agency’s directive to increase enrollment of participants from historically underrepresented populations in clinical trials to improve the strength and generalizability of the evidence to demonstrate safety and/or effectiveness of FDA-regulated medical products, but requests clarification on several points.