FDA issued a proposed rule on September 23, 2020 entitled “Requirements for Additional Traceability Records for Certain Foods”. The proposed rule would establish additional traceability recordkeeping requirements beyond what is already in existing regulations for foods on a newly published “Food Traceability List.” The category of “Herbs (fresh)” is included on the Food Traceability List and provides examples of parsley, cilantro and basil. Food products containing ingredients from the list would be subject to the same traceability requirements up to the point of retail.

Under the proposed rule, the creator or first receiver of listed foods would be required to create a lot-specific “traceability lot code” for the food. This code would then follow the lot through the supply chain until a documented kill step is applied or the lot enters retail sale. Other companies that handle, ship, receive or transform the food throughout the supply chain would also be required to maintain additional records depending upon their operations.

The comment period for the proposed rule closes January 21, 2021. This issue will be subject to discussion by the AHPA Government Relations Committee.

FDA has announced that it will convene three virtual public meetings to discuss the proposed rule:

• November 6, 2020, 8:30 AM-3:30 PM ET
• November 18, 2020 9:30 AM-4:30 PM ET; and
• December 2, 2020 11:30 AM-6:30 PM ET.

Details on how to participate in the public meetings are available in the associated announcement.

In addition, the Food and Beverage Industry Alliance will be hosting a webinar on the proposed rule on November 2, 2020 from 11:30 AM– 1:00 PM ET. As a member of FBIA, all AHPA members are invited to attend this event. Registration is required and available at this address. Participants are encouraged to send questions in advance. Please send any questions you may have to Robert Marriott at rmarriott@ahpa.org.