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IDFA Comments on FDA Food Safety Equivalence Determinations

Jun 13, 2018

The Food and Drug Administration (FDA) in March proposed a new agreement with the European Union (EU) to recognize that the EU’s food safety system for shellfish provides at least an equivalent level of food safety as U.S. systems. This equivalence determination is designed to expand trade opportunities between the two partners and will have implications for FDA’s future efforts to determine a similar agreement for milk and milk products made in other countries.

In comments submitted to FDA late last month, IDFA supported the agency’s interest in pursuing equivalence determinations but stressed that an agreement with EU countries on dairy should remove all barriers to U.S. dairy exports. IDFA also asked for additional insight into FDA’s Grade “A” equivalency determination processes and criteria.

“If FDA assesses that a foreign food safety system for milk and milk products is equivalent to the Grade ‘A’ system, in that it achieves at least the same level of protection, although the foreign standards may differ from those defined in the PMO (e.g., equipment standards), we urge FDA to work through the National Conference on Interstate Milk Shipments to ensure equal flexibility is applied for U.S. facilities,” IDFA said.

In addition to the European Union, New Zealand, Mexico and Canada also have requested equivalence determinations for milk and milk products. FDA’s assessment of the New Zealand system is by far the furthest along, but FDA officials have indicated that publishing a proposed assessment is not yet imminent.

Read IDFA’s comments here.

For more information contact John Allan, IDFA vice president of regulatory affairs and international standards, at

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