Comment from International Fresh Produce Association
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Summary: The International Fresh Produce Association (IFPA) supports the traceability goals of FSMA 204 but argues that the draft guidance contains ambiguities and fails to account for the operational realities of the produce supply chain. They request clearer definitions on relabeling, distribution center implementation, and initial packer determination, while advocating for standardized data exchange and more feasible methods for tracking lot codes in high-velocity environments.
The International Fresh Produce Association appreciates the opportunity to provide our attached comments.