FDA apparently acknowledged in a meeting with various industry reps they will have to delay the final ruling as they review each of the 20,000 comments received. The minutes of the meeting have not been published yet and the article is behind a paywall.
On the bright side, as we move forward in time, the zinc oxide industry led by ANO is growing capacity at a triple digit rate. One of the more common complaints the FDA has likely received is that the industry doesnt have the capacity to meet US market demand if only zinc oxide and titanium dioxide are GRASE. This will no longer be the case one to two years out.
I suspect a first half or capacity update will easily knock out that 100k sell order.
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