AHPA joins FBIA coalition seeking comment period extension for FDA traceability proposed rule

AHPA joins FBIA coalition seeking comment period extension for FDA traceability proposed rule

Request seeks deadline be extended by 60 days, to March 24, 2021.

Published: Thursday, November 5, 2020

The American Herbal Products Association (AHPA) joined a coalition of organizations headed by the Food and Beverage Issue Alliance (FBIA) to request a comment period extension for FDA’s recently published proposed rule on food traceability. AHPA has previously reported on the proposed rule in this AHPA Update.

FDA issued the 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 List. 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 current comment period for the proposed rule is 120 days, ending January 21, 2021. AHPA and the coalition of 19 organizations note the complexity of the rule, limitations imposed by the COVID-19 pandemic, a limited period scheduled public meetings and the presence of multiple public holidays during the current comment period. The organizations request that the comment deadline for the proposed rule be extended by 60 days, to end March 24, 2021.


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