The agency has proposed that when companies make nutrient content or health claims on food packaging based on (a) new food technology or new use of existing technology (b) nonstandardized testing procedures or (c) information available only to the manufacturer the companies be required to maintain records that support the claims. Further those records must be made available to FDA upon request. Access to such records is necessary says FDA to ensure the validity of label claims when the agency lacks resources to conduct its own tests. The requirement's impact is minimal since companies must have compiled test results and records to make the claim in the first place notes the agency. Food processors say this is needless regulation that grants too much authority to FDA. Both the National Food Processors Association (NFPA) and the American Frozen Food Institute (AFFI) submitted comments to FDA stressing the agency lacks legal authority to require mandatory access to company records.