GOED Advocacy

GOED advocates for the increased consumption of EPA and DHA worldwide with scientists, regulators, and other international stakeholders in nutrition.

As part of ‘Operation Stork Speed’ in the United States, GOED submitted a recommendation to the Food and Drug Administration (FDA) to establish requirements for the mandatory addition of DHA and arachidonic acid (ARA) to infant formula. GOED’s last two reports on ‘Operation Stork Speed’ were in the GOED Currents from 18 August 2025 and 9 June 2025.
Comments on Public Consultation No. 1,324: Proposal for a Normative Instruction that establishes the specifications for the identity, purity and composition of ingredients authorized for use in food (concerns about inadequate representation of Schizochytrium oils) - Brazilian Health Regulatory Agency (ANVISA) - (July 30, 2025)
Request to add DHA algal oil to CAN/CGSB-32.311-202X (Organic production systems - Permitted Substances Lists) - Canadian General Standards Board - (July 29, 2025)
Letter to DG Sante providing feedback on proposed mineral oil hydrocarbon regulations - European Commission DG SANTE, Unit E2 - Food processing technologies and novel foods - (July 3, 2025)
Request to update EPA and DHA’s purported risk of bleeding in Food safety in personalized nutrition - FAO of the UN - (June 2, 2025)
Letter to US Department of Commerce Requesting Tariff Exemption for Omega-3s - United States Department of Commerce - (May 7, 2025)
Comments supporting the removal of CAS numbers included in the fish oil listing at 7 CFR 205.606 - United States National Organic Standards Board (NOSB) - (April 10, 2025)
Comments on the Scientific Report of the 2025 Dietary Guidelines Advisory Committee (DGAC)- Secretaries of HHS and USDA - (February 10, 2025)

Comments on the research protocol for Dietary Saturated Fat Replacement and Plasma Lipid and Cardiovascular Events with focus on key questions - Center for Evidence and Practice Improvement Agency for Healthcare Research and Quality - (December 19, 2024)
Comments on the research protocol for Polyunsaturated Fatty Acids and Plasma Lipid and Cardiovascular Events, along with a workbook of studies (classified by outcomes) - Center for Evidence and Practice Improvement Agency for Healthcare Research and Quality - (December 19, 2024)
Comments on the research protocol for Dietary Total Fat Intake and Dietary Polyunsaturated Fatty Acid Intake and Child Growth and Development Outcomes: A Systematic Review - Center for Evidence and Practice Improvement Agency for Healthcare Research and Quality - (December 18, 2024)
Request to remove the Anisidine Value requirement for krill oil - Food Safety and Standards Authority of India (FSSAI) - (November 25, 2024)
Request to extend the deadline for submission of the supplemental evidence and data (SEAD) for two of the three fat-related protocols to be used to conduct the reviews that will facilitate updating the dietary reference intakes (DRI) for dietary fat and fatty acids - US Agency for Healthcare Research and Quality (AHRQ) - (November 20, 2024)
Comment on retaining fish oil on the list of nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as “organic.” - US National Organic Standards Board (NOSB) - (September 30, 2024)
Letter of Commitment - United Nations Global Compact - (May 16, 2024)
Comments on the relisting of fish oil in 7 CFR §205.606, regarding nonorganic ingredients in organic processed products - US National Organic Standards Board (NOSB) - (March 28, 2024)
Comments concerning the Notification of the Ministry of Public Health (No. ...) B.E..... Issued under the Food Act B.E. 2522 Regarding Oils and Fats (No. 2) - Thailand Food and Drug Administration - (March 21, 2024)
Statement on proposed legislation for establishing maximum limit for MOAH for the food additive mixed tocopherols - European Commission - (March 13, 2024)
Comments regarding the proposed SANTE PLAN 2023/2345 Rev.1. and associated “Discussion paper as regards maximum levels for MOAH in food." - European Commission - (February 22, 2024)
Comments regarding Proposed Changes to Fish Oil Monograph - Health Canada - (February 5, 2024)

Comments on the proposed rule for the Revocation of Uses of Partially Hydrogenated Oils in Foods - US FDA - (October 19, 2023)
Proposed Fees for Natural Health Products (NHP) - Health Canada - (August 10, 2023)
Request to increase the daily EPA+DHA upper limit from three grams to five grams - Panama National Directorate for Medical Devices - (August 2, 2023)
Recommendation for the minimum level of DHA in follow-on formula - Food Standards Australia New Zealand’s (FSANZ) - (June 27, 2023)
Request to correct the compositional guideline for 'DHA-rich oil derived from microalgae Schizochytrium sp.' permitted for use in listed medicines - Australia's Therapeutic Goods Administration (TGA) - (May 19, 2023)
Comments to include EPA in Malaysia's nutrient content declaration - Ministry of Health Malaysia - (April 28, 2023)
Comments to include seafood in the definition of “healthy” and a request to include EPA and DHA as nutrients to encourage - The US Food and Drug Administration (FDA) - (Feb 16, 2023)
Suggestions to expand the definition of "highly refined oil" - The US Food and Drug Administration (FDA) - (Jan 30, 2023)

Recommendation to remove the ranges for all fatty acids except EPA and DHA - Thailand Food and Drug Administration - (Oct 20, 2022)
Recommendation to remove the mention of anhydrous fat in a standard for fish oils - Thailand Food and Drug Administration - (Oct 20, 2022)
Proposal for New Work for a Standard for Microbial Omega-3 Oils - Codex - (Oct 3, 2022)
Request to reactivate a discussion on the European Food Safety Authority’s (EFSA) positive scientific opinion on the substantiation of a health claim related to DHA and its contribution to normal brain development - European Commission - (Sept 7, 2022)
Request to not include fish oils in the Standard for Edible Fats & Oils Not Covered by Individual Standards since there is a separate Codex Standard for Fish Oils - Public Authority for Food and Nutrition (PAFN) of Kuwait - (Aug 3, 2022)
Comments on health foods with fish oil not be required a warning statement since it lacks scientific substantiation - Taiwan Food and Drug Administration (FDA) - (Aug 1, 2022)
Comments on the Draft Guidance for Industry: Policy Regarding Certain New Dietary Ingredients and Dietary Supplements Subject to the Requirement for Pre-market Notification - US Food and Drug Administration (FDA) - (July 19, 2022)
Comments on the White House Conference on Hunger, Nutrition, and Health - US White House Office of Public Engagement - (July 15, 2022)
Comments on the Food Safety and Standards (Food Products Standards and Food Additives) Amendment Regulations, 2022 - Food Safety and Standards Authority of India (FSSAI) - (July 11, 2022)
Proposal on maximum limits of process contaminants in food supplements containing special fatty acids - FSE - (Jan 21, 2022)
Request for a change in the maximum limits for trans fat and free fatty acids in fish oils - Deputy Director General of Foreign Trade - (Jan 11, 2022)
Comments on front-of-pack nutrition labeling and nutrient profile setting - EFSA - (Jan 8, 2022)

Comments on Registration Regulations (Decree 248) and Administrative Measures (Decree 249) - Chinese Customs - (December 22, 2021)
Comment on Proposed Fatty Acid Specifications for Krill Oil - Korean Ministry of Food and Drug Safety - (November 18, 2021)
Request for Early Input on Proposed Chapter on Impurities in Ingredients and Supplements - US Pharmacopeia - (October 20, 2021)
Comments Regarding the Fish Oil Annotation - US National Organic Standards Board (NOSB) - (September 28, 2021)
Comments Regarding the Nutrient Composition of Infant Formula Products - Food Standards Australia New Zealand (FSANZ) - (August 30, 2021)
Request to Change Fatty Acid Specifications for Algal Oils from Schizochytrium - Thai Food and Drug Administration - (August 23, 2021)
Comments on Partial Revision of the Standards and Specifications of Health Functional Foods - Korean Ministry of Food and Drug Safety - (June 11, 2021)
Review of USP Draft Monograph for Algal DHA - United States Pharmacopeia - (May 21, 2021)
Comments regarding Methods of Analysis for Fats and Oils - Codex Alimentarius Commission - (May 10, 2021)
Advice to Amazon.com on the Proper Storage and Distribution of EPA+DHA Omega-3 Dietary Supplements - Amazon.com - (May 3, 2021)
Oral Comments on Proposed Changes to the Fish Oil Annotation - US National Organic Standards Board (April 22, 2021)
Comments on Proposed Changes to the Fish Oil Annotation - US National Organic Standards Board (April 9, 2021)
Comments on the Labelling of Foods Composed of or Containing Cultured Seafood Cells - US Food and Drug Administration (March 8, 2021)
Request Regarding the Import Policy’s Maximum Limits for Trans and Free Fatty Acids for Fish Oils - Indian Directorate General of Foreign Trade (February 1, 2021)

Comments in Support of the Revision of the Arsenic Standard in Fish Oil - South Korea Ministry of Food and Drug Safety International Cooperation Office (November 30, 2020)
Comments Related to Restrictions on the Use of Fish Oil as a Food Material - Taiwan Food & Drug Administration (October 13, 2020)
Brief Comments Related to Unqualified "Made in the USA" Claims - US Federal Trade Commission (September 14, 2020)
Written Comments Regarding EPA+DHA and the Dietary Guidelines for Americans - US Departments of Agriculture and Health and Human Services (August 13, 2020)
Additional Comments Encouraging the Addition of DHA to Complementary Foods for Infants and Young Children - European Commission (July 24, 2020)
Comments to the Codex Committee on Methods of Analysis and Sampling (CCMAS) in response to CL 2020/29/OCS-MAS (June 29, 2020)
Comments Concerning Proposed Changes to the Fish Oil Annotation - US National Organic Standards Board (April 2, 2020)
Comments on the Relationship between Omega-3 Fatty Acids and Pregnancy-Related Health Outcomes - Dietary Guidelines Advisory Committee, USDA (February 7, 2020)
Comments on Non-Organic Agricultural Ingredients to be Used for the Production of Processed Organic Food - European Commission (January 7, 2020)

Comments Answering a Question from the Pregnancy and Lactation Subcommittee - USDA Food and Nutrition Service (October 23, 2019)
Comments Concerning the Relisting of Fish Oil Among Nonorganically Produced Agricultural Products Allowed as Ingredients in or on Processed Products Labeled as “Organic" - US National Organic Standards Board (October 3, 2019)
Joint publication with IADSA with IADSA for policy makers (September 30, 2019)
Comments Regarding the Scientific Evidence Considered While Preparing US Dietary Guidelines - UDSA Food and Nutrition Service (July 24, 2019)
Comments Explaining the Lawful Status of Omega-3 Ingredients in the US - US Food and Drug Administration (July 15, 2019)
Comments Encouraging the Addition of DHA to Complementary Foods for Infants and Young Children - European Commission (June 27, 2019)
Comments in Support of Adoption of CODEX Fish Oil Standards - South Africa, Directorate: Food Control (June 20, 2019)
Comments in Advance of the 51st Session of the Codex Committee on Food Additives (Submitted 18 March 2019)
Comments in Advance of the 26th Session of the Codex Committee on Fats and Oils (Submitted 22 February 2019)
Comments in Support of Fish Oil Relisting - US National Organic Standards Board (4 April 2019)
Recommendation of AOCS Cd 8b-90 as a Peroxide Value Testing Method - South Korea Ministry of Food and Drug Safety (February 28, 2019)
Comments in Support of Adoption of CODEX Fish Oil Standard - Egyptian Organization for Standardization and Quality (February 13, 2019)
Provision of Information on the Mitigation Approaches used by Fish Oil Refiners - CCCF Electronic Working Group (January 9, 2019)

Provision of Information on Mitigation Approaches used by Fish Oil Refiners - CCCF Electronic Working Group (November 30, 2018)
GOED Comments re: Proposed Draft NRV-NCD for EPA and DHA - CCNFSDU (November 14, 2018)
Consultation on draft levels for 3-MCPD for vegetable and fish oils and glycidol esters for fish oils - European Commission (October 30, 2018)
Proposed Draft NRV-NCD for EPA and DHA - CCNFSDU (October 26, 2018)
Proposed Draft NRV-NCD for EPA and DHA - US Delegation to CCNFSDU (October 26, 2018)
Comprehensive, Multi-Year Nutrition Innovation Strategy - US FDA (October 8, 2018)
Rosemary extract as a food additive - Food Standards Australia New Zealand (August 30, 2018)
Comment re: Standard and Specification of Health Functional Food - South Korea Ministry of Food and Drug Safety (June 28, 2018)
Changes to rules covering crude fish oil production in Peru - DG SANTE (June 9, 2018)
Provision of Information on the Levels of 2-MCPD, 3-MCPD, their Esters, and Glycidyl Esters in EPA/DHA (May 1, 2018)
Request for Comments on Proposed Draft NRV-NCD for EPA+DHA - CCCF Electronic Working Group (April 27, 2018)
Comments on Draft Resolution Number 457 - Brazilian Health Regulatory Agency (ANVISA) - April 6, 2018
Request for Comments on Dietary Guidelines - USDA and US Health and Human Services (March 27, 2018)
General Standard for Food Additives - Chinese Secretariat of CCFA (March 16, 2018)Request to align krill oil standards with the Codex standard for fish oils by removing the Peroxide Value (PV) and Totox number criteria