Photo of Martin Hahn

Partner, Washington, D.C.

Martin Hahn uses his background in food technology and his comprehensive understanding of the laws governing the food industry to navigate clients through the myriad regulatory and business issues impacting the industry from farm to table. He recognizes the demands placed on his clients and finds innovative and creative solutions, particularly when responding to observations raised by regulators  during inspections. Whether the issue involves obtaining the authorization of a new food or dietary ingredient, complying with manufacturing requirements, labeling or advertising, product recalls, or enforcement, Martin serves as an effective advisor and advocate.

Martin's career has touched on almost every issue impacting the food industry. He has a comprehensive understanding of the laws affecting the labeling and advertising of foods, dietary supplements, infant formulas, medical foods, and foods for special dietary use. He helps clients anticipate new trends and develop the data that is needed to distinguish their products from others on the market. With his understanding of science and technology in the food industry, Martin provides assistance in obtaining regulatory authorizations to market new food ingredients, food packaging materials, and dietary ingredients. He also assists clients in responding to proposed regulations and draft guidance, as well as, tracks and keeps his clients apprised of the latest trends in class action law suits and helps clients anticipate new regulatory initiatives.

Martin grew up on a farm and worked in food processing plants before going to law school. His hands-on experience in the field and degree in food technology allow him to better understand the challenges his clients face in complying with the laws impacting food manufacturing. He understands Hazard Analysis Critical Control Point (HACCP) and the regulations under the Food Safety Modernization Act (FSMA).

Tell me if you’ve heard this one before – the regulatory issues surrounding CBD will be completely resolved after a certain “legislative fix” is passed.  Remember all of the articles in December 2018 declaring CBD legal after the passage of the 2018 Farm Bill? Don’t expect Congress or FDA to wave a magic wand and

On August 4, 2020, the Office of Environmental Health Hazard Assessment (OEHHA), the lead agency that implements California’s Proposition 65 (Prop 65), proposed to adopt a new regulation that would significantly change the warning requirements for listed chemicals formed by the cooking or heat processing of foods. The proposed regulation would provide that intake of

The U.S. Department of Agriculture’s (USDA’s) Agricultural Marketing Service (AMS) is seeking comments on recommendations to update the List of Bioengineered Foods (List) under the National Bioengineered Food Disclosure Standard (NBFDS). AMS seeks comment on four issues: (1) whether it should add insect-resistant sugarcane to the List; (2) whether it should add the modifier “virus-resistant”

We would like to bring to your attention to three recent developments related to California’s Proposition 65. On July 8, the Office of Environmental Health Hazard Assessment (OEHHA) adopted three safe harbor levels or maximum allowable levels (MADLs) for the chemical chlorpyrifos. On June 22, the United States District Court (Eastern District of California) entered

The U.S. Department of Agriculture’s (USDA’s) Agricultural Marketing Service (AMS) issued two final guidance documents providing industry stakeholders with instructions on how to implement certain requirements of the National Bioengineered Food Disclosure Standard (NBFDS). The agency’s Guidance to Ensure Acceptable Validation of a Refining Process outlines steps for validating that a refining process makes modified

The Council for Responsible Nutrition (CRN) submitted a citizen petition to the Food and Drug Administration (FDA) requesting that FDA:

  1. FDA exercise its statutory authority to establish a regulation under which hemp-derived cannabidiol (CBD) may be legally marketed as a dietary ingredient;
  2. Clarify when a hemp-derived substance is subject to the preclusion provisions of 21

In March, the Food and Drug Administration (FDA) issued guidance documents, first revised on March 27, temporarily relaxing certain regulatory requirements for the production of alcohol-based hand sanitizers, to respond to the increased demand for hand sanitizer products during the novel coronavirus crisis. Yesterday, FDA issued additional minor updates to these documents. Notably, FDA provides

As the novel coronavirus crisis continues to escalate, the demand for hygienic products such as hand sanitizer has dramatically increased. In response, many businesses, such as food and industrial and beverage alcohol manufacturers, are seeking to produce alcohol-based hand sanitizers using certain food grade materials, or to produce alcohol to be used in production of

The U.S. Food and Drug Administration (FDA) announced yesterday two policies to provide flexibility with respect to nutrition labeling requirements during the COVID-19 pandemic. First, the agency committed to work cooperatively with all manufacturers for the remainder of the year regarding the use of updated Nutrition and Supplement Facts labels and will not focus on

As the novel coronavirus (COVID-19) crisis continues to present new questions and challenges, the U.S. Food and Drug Administration (FDA) continues to update its website to provide additional information and guidance to the food industry. Since FDA initially issued guidance last week, the agency has supplemented this guidance with six additional questions and answers concerning