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A Final Word on FDA's Traceability Rule

Part 3 of 3


In our two prior posts we talked about the FSMA Final Rule: Requirements for Additional Traceability Records for Certain Foods (FDA’s Food Traceability Final Rule) and gaps in food traceability from company to company. If you haven't read our two previous posts on FDA's Traceability Rule, I suggest you go back and take a look.


We won’t go through the finer points of the Rule in this post, but there are some related things you should know.


The Food Traceability Final Rule will likely tie in with your Foreign Supplier Verification Program

Food importers may also have specific recordkeeping requirements under the Final Rule. For example, an importer may be subject to the rule if they take physical possession of a food listed on the FTL. An importer that coordinates the importation process but does not take possession of the food would not be subject to the requirements under this Final Rule.


If your company imports food products on the FTL, or you have brokers or importers that facilitate the importation process, it is time to review your Foreign Supplier Verification Program (FSVP). Communication with your brokers, importers, and foreign suppliers is necessary to determine who is maintaining the appropriate traceability data and how it will be communicated to your operation.


An additional documented/implemented program will be required within your Food Safety Plan

A documented Traceability Plan will need to be implemented for those who are, or may be, subject to the new Rule. The plan will need to contain various pieces of information, including:

  • Recordkeeping procedures compliant with the new Rule

  • Procedures to identify if foods you manufacture, process, pack, or hold are on the FTL

  • Description of how lot codes are assigned to foods on the FTL

  • Point of contact within the company that can answer questions on the traceability plans and records being maintained.

New traceability recordkeeping requirements will be required for some, but not all

The goal of the new Food Traceability Final Rule is to speed identification and removal of potentially contaminated food from the market. To do that, the new rule establishes traceability recordkeeping requirements beyond those in existing regulations, but only for those that manufacture, process, pack, or hold foods listed on the FTL.


As always, there are exemptions to whom the final rule applies. For example, some farms, operations with commingled raw agricultural commodities (RACs), fishing vessels, retail food establishments, restaurants, and other specified operations have full or partial exemptions from the rule.


Determine if you produce or use the foods on the Food Traceability List and make sure you are in compliance with this new Food Traceability Final Rule.


Contact Kidder Consulting Services at (800) 918-8788 or info@kidder-consulting.com to start the development and implementation process for your new traceability recordkeeping procedures, Traceability Plan, and supporting documentation.


See FDA’s website for further details on FDA’s Food Traceability Final Rule.


Kidder Consulting Services

Kidder Consulting Services works with food companies and private equity firms (clients in the food industry) to bring a strategic, risk-based, proactive approach to food safety challenges. With over 20 years in industry, our experience includes food safety, regulatory compliance, supply chain management, operations, and due diligence work. Call or email us today to find out how we can help you address your food safety needs.


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