# PUBLIC COMMENT ON PROPOSED REGULATIONS: Mandatory Manufacturing Cost Survey Advanced Notice of Proposed Rulemaking

**Submitted by the Center for Federal Accountability (CFA)**  
**Document Number:** 2026-04013

## Executive Summary

The Center for Federal Accountability submits this draft comment to support timely public record participation while full model-backed legal analysis is queued. This draft identifies baseline accountability concerns and preserves key issues for agency consideration before the close of comments.

## Table of Authorities (to be finalized)

- Administrative Procedure Act (5 U.S.C. 551 et seq.)
- Agency enabling statute and implementing regulations (rule-specific citations to be finalized)

## Key Concerns

- The agency should clearly identify statutory authority for each material requirement in the proposal.
- The agency should provide transparent cost, burden, and implementation assumptions with reproducible methodology.
- The agency should address foreseeable operational risks and unintended consequences for regulated parties and the public.

## Preliminary Analysis

This preliminary draft is generated from the available Federal Register text excerpt below and is intended to preserve issues for the rulemaking record. A full model-backed CFA legal analysis can be substituted in a subsequent revision.

> Federal Register, Volume 91 Issue 39 (Friday, February 27, 2026) [Federal Register Volume 91, Number 39 (Friday, February 27, 2026)] [Proposed Rules] [Pages 9732-9733] From the Federal Register Online via the Government Publishing Office [ www.gpo.gov ] [FR Doc No: 2026-04013] ======================================================================== Proposed Rules Federal Register ________________________________________________________________________ This section of the FEDERAL REGISTER contains notices to the public of the proposed issuance of rules and regulations. The purpose of these notices is to give interested persons an opportunity to participate in the rule making prior to the adoption of the final rules. ======================================================================== Federal Register / Vol. 91, No. 39 / Friday, February 27, 2026 / Proposed Rules [[Page 9732]] DEPARTMENT OF AGRICULTURE Agricultural Marketing Service 7 CFR Part 1171 [Doc. No. AMS-DA-25-0585] RIN 0581-AE47 Mandatory Manufacturing Cost Survey Advanced Notice of Proposed Rulemaking AGENCY: Agricultural Marketing Service, USDA. ACTION: Advance notice of proposed rulemaking. ----------------------------------------------------------------------- SUMMARY: This advance notice of proposed rulemaking (ANPR) seeks input from stakeholders on the development of mandatory surveys of dairy production cost and product yield information, as authorized by the One Big Beautiful Bill Act of 2025 (OBBBA). USDA's Agricultural Marketing Service (AMS) seeks comments on the manufacturing cost and product yield data to be collected, the collection process, cost calculation methodologies, verification processes, and data reporting. Information received from public comments will inform USDA's approach to this legislative mandate. DATES: Comments must be received by March 30, 2026. ADDRESSES: Comments may be submitted through the Federal e-rulemaking portal at https://www.regulations.gov and should reference the document number, date, and page number of this issue of the Federal Register. Written comments may be submitted via mail to USDA/AMS/Dairy Programs, Stop 0225-Room 2530, 1400 Independence Avenue…

## CFA Recommendations

1. Publish a clear crosswalk from each proposed requirement to its statutory basis.
2. Expand and disclose the quantitative assumptions used in cost-benefit analysis.
3. Provide implementation alternatives and phase-in options to reduce compliance risk.
4. Extend or reopen comment if substantial updates are made after publication.

## CFA Contact

Center for Federal Accountability (CFA)  
8401 Mayland Dr # 7387  
Richmond, VA 23294  
policy@federalaccountability.com | https://www.federalaccountability.com/

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_Generated via cursor provider fallback at 2026-03-23T20:58:36.712986+00:00._