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What Does “Comments About Existing Terms” Mean?

Comments about existing terms are feedback on entries already listed in a glossary or database. In rulemaking, the phrase can instead refer to public comments on proposed definitions.
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“Comments about existing terms” usually means feedback or explanatory notes on terminology entries that already exist in a glossary or database. It is different from suggesting a new term. The phrase is not a universal technical or legal term, though: in rulemaking, it can also refer to public comments on definitions in a proposed regulation.

What comments about existing terms mean in a glossary or database

In a terminology resource, a comment about an existing term is an observation attached to an entry already in the resource. It might ask for clarification, flag an issue, or explain how the term is used. A comment does not necessarily change the term or its definition, and a user-submitted note is not automatically an authoritative definition.

Thierry Fontenelle’s account of the European Chemicals Agency’s ECHA-term database distinguishes comments on existing entries from suggestions for new terms: “A feedback mechanism also allows users to suggest new terms (around 100 terms are added every year) and to provide comments about existing entries.” The reported annual addition figure is approximate and historical, not a current rate.

Commenting on an entry versus proposing a new one

  • Comment on an existing term: respond to or explain an entry already listed.
  • Suggest a new term: ask the resource’s editors to consider adding an entry that is not there.

These are separate kinds of feedback, even when one system accepts both. The ECHA-term example illustrates that distinction; it does not establish a universal workflow for terminology databases.

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What the phrase means in regulatory rulemaking

In a legal or regulatory setting, “comments” may mean formal public submissions about a proposed rule, including its definitions. An agency reviews those submissions and can revise a definition, clarify it, or leave it unchanged. The outcome depends on the agency’s process and the specific rule; submitting a comment does not guarantee a change.

Example: DoD’s CMMC final rule

In its 2024 Cybersecurity Maturity Model Certification (CMMC) final-rule discussion, the Department of Defense addressed requests to clarify, add, remove, or modify terms and definitions. The department changed some terminology and said that terms it left unchanged were sufficiently defined and appropriately referenced. This shows that public feedback can inform revisions, but requests are not automatically accepted. Read the CMMC final rule in the Federal Register.

Example: proposed HIPAA Security Rule changes

In a 2025 proposed HIPAA Security Rule, the Department of Health and Human Services proposed adding ten terms and modifying fifteen existing definitions, and invited public comments. One proposed change would expand “access” to include deleting and transmitting information. These are proposals, not final requirements; the proposal document alone does not establish what wording, if any, was later adopted. Read the HIPAA Security Rule proposal in the Federal Register.

How to tell which meaning applies

Context What the comment concerns Who responds Possible effect
Glossary or terminology database An entry already in the resource Typically the resource’s editors or maintainers; the ECHA-term account describes a feedback mechanism but does not specify a universal review process The resource may clarify or update an entry, or leave it as it is; a submitted comment is not itself an official definition
Public rulemaking A definition or other provision in a proposed regulation The agency responsible for the rule The agency may revise, clarify, or retain the definition in its final rule

Look at where the comment is posted or filed and what document it refers to. A note attached to a database entry is not the same thing as a formal submission to an agency, and the ECHA-term feedback process does not govern regulatory comments.

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What the phrase does not establish

Without context, the phrase does not identify a particular database, rule, or official procedure. It is best read as a plain-language description rather than a fixed technical term. To interpret a specific use, check whether the surrounding material discusses an existing glossary entry or a draft legal definition—and whether the document is a proposal or a final rule.

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