The International Fresh Produce Association (IFPA) has shared its initial reactions to the newly published rule under the Food Safety Modernization Act—Requirements for Additional Traceability Records for Certain Foods (Food Traceability Final Rule). The final rule was released on November 15, 2022, and sets additional traceability recordkeeping requirements for companies who manufacture, process, pack, or hold foods included on the Food Traceability List (FTL), which includes fresh produce commodities.

IFPA expresses that it is committed to working with the U.S. Food and Drug Administration (FDA) to help its members understand and comply with the requirements of the final rule. The association also stated that it appreciates that major concerns about the draft rule have been addressed in the final rule.

IFPA also highlighted important components of the final rule, including those that align with issues for which both the Produce Marketing Association and United Fresh, the parent organizations of IFPA, advocated:

  • The Rule becomes effective 60 days after it is published in the Federal Registry. This is estimated to be January 20, 2023
  • The enforcement date has been pushed back 12 months to January 20, 2026
  • Record keeping requirements for first receivers regarding growing location and harvesting information have been moved to the initial packer
  • The requirement for contact information of the person who assigned a lot number has been replaced by including a point of contact within a traceability plan
  • The final rule removed the requirement to capture, store, and share the entry number assigned to imported food.

IFPA encourages its members to participate in upcoming opportunities to learn more about how the Food Traceability Final Rule impacts their businesses. The association recommends two upcoming events where industry members can learn more about the final rule and its impact on industry, including a webinar hosted by Food Safety Magazine.

  • November 29, 2022 2:00–3:00 P.M. ET: IFPA’s traceability expert, Ed Treacy, will join a panel with GS1 and FDA officials, including Frank Yiannas, FDA Deputy Commissioner for Food Policy and Response; Captain Kari Irvin, M.S., Deputy Director, Office of Coordinated Outbreak Response and Evaluation (CORE) within FDA’s Center for Food Safety and Applied Nutrition (CFSAN); and Katherine Vierk, M.P.H., Director of FDA’s Division of Public Health Informatics and Analytics. Register here.
  • December 14, 2022, 12:00–1:00 P.M. ET: IFPA will host a Virtual Town Hall, titled, “FSMA 204 Traceability Final Rule” moderated by Ed Treacy and featuring a panel of experts, including: Steve Roosdahl, Vice President of Operations at The Oppenheimer Group and co-chair of PTI; Elizabeth Fawell, Partner of law firm Hogan Lovells; and Joan Studley, Product Manager of HarvestMark with iFoodDS. Register here.

IFPA will provide a full analysis on the final rule in an upcoming update.