Questions and Answers About Requirements for Additional Traceability Records for Certain Foods: Guidance for Industry - Draft Guidance

The International Foodservice Distributors Association (IFDA) supports the draft guidance but requests specific revisions to provide greater flexibility for distributors. They argue for clearer provisions regarding inaccurate supplier records, multi-case pallet tracking, and the responsibilities of third parties to ensure the rule is manageable and does not impose undue burdens.

The Consumer Brands Association supports the FDA's efforts to provide clarity on the Food Traceability Rule but requests additional flexibilities to reduce regulatory burdens. Specifically, they advocate for principle-based frameworks to avoid case-level tracking, exemptions for intracompany shipments, and clear "best practice" recommendations for location descriptions.

The Food Industry Association (FMI) supports the Draft Guidance but argues that it lacks sufficient flexibility to address significant operational burdens. They request specific modifications, including allowing for a range of lot codes at the distribution level, using GTINs as source references, exempting intracompany shipments, and establishing a safe harbor for entities receiving incomplete data from suppliers.