The Food and Drug Administration (FDA) in September released draft guidance on food recalls, clarifying how and when it plans to issue information on retailers that may have received affected products. Specifically, FDA said it would focus on releasing retailer information for foods that aren’t easily identifiable, such as those without packages, during a recall. In comments submitted last week, IDFA agreed with FDA’s scope and stressed that packaged foods, which include the majority of dairy foods, should not be subject to this kind of disclosure. Sharing on-product information, not retailer information, is the most effective way to recall packaged products, IDFA said.
“Information regarding the name of the product, manufacturer, labeling, lot code or date code and other information that is publicized today is of most relevance to consumers as opposed to retailer information,” IDFA said.
By listing general retailer locations or creating lists of names that are too long to cover in TV or radio news, FDA could cause unnecessary consumer confusion, IDFA said, and this would run counter to the agency’s intended goals.
“Avoidance of incomplete and/or potentially conflicting information about recalls is therefore critical, and the focus should instead be on product identification versus retail locations,” IDFA said.
IDFA also asked FDA to include more examples in the guidance of what FDA plans to disclose about retailers during a Class II recall, which applies to recalled foods that may cause temporary or medically reversible adverse health consequences, or where the probability of serious adverse health consequences is remote. IDFA also stressed that FDA should wait until it has categorized a recall before sharing retailer information.
“Certainly, IDFA appreciates the importance of communicating recalls as quickly as possible and that this may take place before classification has occurred. Nonetheless, recall classification can help ensure that the criteria for publicizing recall consignees have been met. This is important because confidential commercial information should only be disclosed where necessary to protect the public health and effectuate a recall,” IDFA said.
IDFA also asked FDA to provide additional information on how it would collect retailer information, such as who it will ask to supply this information and in what format.
Read IDFA’s comments here.
For more information, contact John Allan, IDFA senior vice president of regulatory affairs and international standards, at firstname.lastname@example.org.