The FDA is proposing to establish additional traceability recordkeeping requirements (beyond what is already required in existing regulations) for foods FDA has designated for inclusion on the Food Traceability List. Under the proposed rule, dried herbs and spices do not appear on the Food Traceability List. Additionally, in 2021, FDA clarified the listing for herbs (fresh) and peppers (fresh) to include the (fresh) designations, and that the food traceability list applies only to the fresh varieties of the listed commodities. It is also notable that commingled raw agricultural commodities are partially exempt from any requirements under the proposed rule, although manufacturers are still required to keep records in compliance with the Bioterrorism Act.
FDA Resources |
ASTA and Industry Resources |
Proposed Rule For Food Traceability The FDA proposed rule outlining the additional recordkeeping requirements is available. |
FBIA Webinar on Food Traceability Proposed Rule Recording and slides from a webinar, presented by Hogan Lovells, provides an overview of the Proposed Rule. |
Food Traceability List This List designates foods for which additional recordkeeping requirements are appropriate and necessary to protect public health, and to establish those recordkeeping requirements. |
ASTA Comments ASTA’s comments were submitted to the FDA on February 22, 2021. The comments focus on clarifications to the Food Traceability List, support the partial exemption for comingled raw agricultural commodities, request a full exemption for foods that undergo a kill step, and other issues. |