FDA clarifies applicability of food traceability rule with new draft Q&A guidance
The FDA has issued draft Q&A guidance clarifying how the food traceability rule applies across the supply chain, including manufacturers, farms, retail food establishments, and restaurants. The 31-page document addresses implementation challenges ahead of the revised compliance timeline and responds to questions surrounding exemptions, transformation events, recordkeeping responsibilities, and traceability lot codes.
The guidance provides additional detail on issues such as pallet breaking, intracompany shipments, ad hoc restaurant purchases, continuous processing, and the distinction between fresh-cut and trimmed produce — all areas that have generated uncertainty as industry prepares for enforcement.
This AgencyIQ analysis examines key clarifications, enforcement signals, and open questions companies should evaluate as they refine compliance strategies.
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