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Small Entity Compliance Guide: Requirements for Additional Traceability Records for Certain Foods: What You Need to Know About the FDA Regulation

FinalHuman Foods Program05/18/2023

Description

On January 4, 2011, President Obama signed the FDA Food Safety Modernization Act (FSMA) (Pub. L. 111-353) into law.  As a component of FSMA’s overhaul of U.S. food safety law to better ensure the safety and security of the nation’s food supply, section 204(d) of FSMA requires that FDA establish recordkeeping requirements for facilities that manufacture, process, pack, or hold foods the Agency designates as high-risk to facilitate the rapid and effective traceability of such foods.  These recordkeeping requirements are additional to the food traceability requirements under section 414 of the Federal Food, Drug, and Cosmetic Act (FD&C Act) (added to the FD&C Act in title III, subtitle A, section 306, of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (the Bioterrorism Act) (Pub. L. 107-188)) and the implementing regulations in subpart J ofpart 1 of title 21 of the Code of Federal Regulations(§§ 1.326 to 1.368) (the subpart J regulations). In section 204(d)(1) of FSMA, Congress directed FDA to adopt additional recordkeeping requirements to prevent or mitigate foodborne illness outbreaks and address credible threats of serious adverse health consequences or death to humans or animals resulting from certain foods being adulterated under section 402 of the FD&C Act or misbranded with respect to allergen labeling under section 403(w) of the FD&C Act.

Scope & Applicability

Product Classes

5
Raw Agricultural Commodity

Sprouts in their raw or natural state

RAC

Raw Agricultural Commodities

Sprouts

Specific requirements for growing, harvesting, packing and holding; Specific produce category with unique compliance dates and requirements; Specific category often excluded from general pre-harvest water assessments; Specific produce category with unique vulnerability to microbes; Operations with shorter compliance timelines

Shell Eggs

Subject to specific exemptions based on hen count or treatment

Raw agricultural commodities

RACs; Fruits and vegetables subject to section 419 standards; Referred to as RACs in the context of packing and holding.

Stakeholders

10
Nonprofit food establishment

Charitable entities like food banks and soup kitchens

Transporter

A person who has possession of food for the sole purpose of transporting it.

fishing vessel

Source of food with specific receipt record exemptions

restaurant

Exempt from certain transformation recordkeeping for foods not shipped; Entity type with specific spreadsheet exemptions based on sales; Facility that prepares and sells food directly to consumers for immediate consumption.

retail food establishment

Exempt from certain traceability lot code assignment requirements; Entity type with specific spreadsheet exemptions based on sales; Establishment that sells food products directly to consumers.

First Land-Based Receiver

The person who first receives food from a fishing vessel on land.; Person taking possession of food for the first time on land from a fishing vessel.

Initial Packer

The person who first packs a raw agricultural commodity.

Small Entity

Target audience for the compliance guide

Retail food establishments

Exemption based on annual monetary value of food sold

Restaurants

Entities involved in commercial food preparation

Regulatory Context

Attributes

3
Geographic Coordinates

Specific location data required for farm maps.

Location description

Key contact information for the location where food is handled.

economic hardship

Criterion for granting a regulatory waiver; Basis for requesting or maintaining a waiver

Identified Hazards

Hazards

3
Foodborne illness outbreaks

Risks the Food Traceability Rule aims to prevent or mitigate.

foodborne illness outbreak

Public health risk the rule aims to mitigate; Public health threat requiring rapid identification of recipients

Microorganisms of public health significance

Pathogens that commercial processing must adequately reduce

Related CFR Sections (20)

Related Warning Letters (10)

  • Seafood HACCP/CGMP for Foods/Adulterated/Insanitary Conditions

    Harbor Marine Product Inc.

    2025-12-16
  • Foreign Supplier Verification Program (FSVP)

    V & L Produce, Inc.

    2025-10-28
  • CGMP/Food/Prepared, Packed or Held Under Insanitary Conditions/Adulterated

    Hans Bakery Inc. d/b/a Andersen’s Bakery

    2025-09-30
  • Foreign Supplier Verification Program (FSVP)

    Jalisco Fresh Produce, Inc.

    2025-09-09
  • Seafood HACCP/CGMP for Foods/Adulterated

    Chaohu Daxin Foodstuffs Co., Ltd.

    2025-08-19
  • Foreign Supplier Verification Program (FSVP)

    A.D. Berries @ More LLC

    2025-07-15
  • Seafood HACCP/CGMP for Foods/Adulterated/Insanitary Conditions

    Yongdae Hwangtae Union Corp Daeryung

    2025-06-24
  • Foreign Supplier Verification Program (FSVP)

    Gongora USA Corp

    2025-06-10
  • Food/Prepared Packed or Held Under Insanitary Conditions/Adulterated

    Jack & The Green Sprouts, Inc.

    2025-06-03
  • Foreign Supplier Verification Program (FSVP)

    Amore Produce, LLC

    2025-06-03

See Also (8)

Small Entity Compliance Guide: Requirements for Additional Traceability Records for Certain Foods: What You Need to Know About the FDA Regulation | Guideline Explorer | BioRegHub