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The U.S. Food and Drug Administration (FDA), in November 2022, published a final rule "Requirements for Additional Traceability Records for Certain Foods" designed to improve the agency's ability to rapidly track and trace food through the supply chain. Covered entities – including farms, manufacturers, distributors, retail food establishments, and restaurants – will be required to provide this traceability information to the FDA within 24 hours of an official request, or within some reasonable time to which the FDA agrees. Covered entities are those that manufacture, process, pack, or hold foods on the Food Traceability List (FTL). The only dairy products included in the FTL are certain cheeses, but when used as ingredients in other foods, those foods may also be covered.
It is clear this new regulation will have significant impacts on the food industry that is directly regulated under its provisions, but there will also be spill-over effects on other companies and products.
IDFA and our outside legal counsel, Hogan Lovells US, LLP, presented an in-depth webinar to review the rule and discuss the impacts on the cheese industry and beyond.