Comment from Convenience Distribution Association; Minnesota Wholesale Marketers Association

Summary: The Minnesota Wholesale Marketers Association (MWMA), in conjunction with the Convenience Distribution Association (CDA), argues that the FDA should adopt a flexible option for FSMA Section 204(d) compliance by requiring manufacturers to imprint Traceability Lot Codes (TLC), TLC Sources, and expiration dates directly on case labels, inner packs, and individual packages. They contend that this "imprinting" model is a feasible, long-standing industry practice that avoids forcing distributors, retailers, and restaurants to overhaul their existing business operating systems or software to achieve effective lot-level traceability.