November 15, 2022
Newark, DE. and Washington, D.C. – International Fresh Produce Association (IFPA) has shared their initial reactions to the newly published rule on the Requirements for Additional Traceability Records for Certain Foods (Food Traceability Final Rule). The final rule was released on November 15, and sets additional traceability recordkeeping requirements for companies who manufacture, process, pack or hold foods included on the Food Traceability List (FTL) which includes fresh produce commodities.
“IFPA is committed to working with the FDA to help our members understand and comply with the requirements of the final rule,” said Ed Treacy, VP of supply chain and sustainability at IFPA. “We appreciate that the major concerns we had about the draft rule have been addressed. We encourage our members to participate in upcoming opportunities to learn more about how this rule impacts their business.
Here are highlights from the final rule, including those that align with issues that both PMA and United advocated for:
- The Rule becomes effective 60 days after it is published in the Federal Registry. This is estimated to be January 20, 2023.
- The Enforcement Date has been pushed back 12 months to January 20, 2026.
- The first receiver record keeping requirements of growing location and harvesting information have been moved to the Initial Packer.
- The contract information of the Person who assigned the lot number has been replaced by including a point of contact (i.e. Title of position) within the traceability plan.
- The final rule removed the requirement to capture, store, and share the entry number assigned to imported food.
There are two upcoming events where industry members can learn more about the final rule and the impact on the industry.
- November 29, 2-3 PM Eastern: IFPA’s traceability expert, Ed Treacy, will be join a panel with GSI and FDA officials including with Frank Yiannas, Kari Irvin and Katherine Vierk. Register here.
- December 14, 12-1 PM Eastern: IFPA will host a Virtual Town Hall on “FSMA 204 Traceability Final Rule” moderated by Ed Treacy and featuring a panel of experts including: Steve Roosdahl – VP Operations at The Oppenheimer Group and co-chair of PTI, Elizabeth Fawell, Partner of DC based law firm Hogan Lovells and Joan Studley, Product Manager of HarvestMark with iFoodDS. Register here.
IFPA will provide a full analysis on the full rule in an upcoming update.