NGA Submits Comments on FDA Traceability Rule

February 23, 2021

Washington D.C. – The National Grocers Association (NGA), the national trade association representing the independent supermarket industry, submitted comments yesterday on the proposed U.S. Food and Drug Administration (FDA) rule, “Requirements for Additional Traceability Records for Certain Foods.”

The proposed rule aims to establish additional traceability recordkeeping requirements for persons who manufacture, process, pack or hold foods the FDA has designated for inclusion on the Food Traceability List (FTL). Specifically, the proposed rule requires these entities to establish and maintain records containing Key Data Elements (KDEs) associated with different Critical Tracking Events (CTEs).

“Grocers are the linchpin in our complex farm-to-fork food supply chain, serving as the touch to the consumer in the marketplace for food, and often as the first source customers look to for information during a food recall,” said Greg Ferrara, NGA president and CEO. “While we appreciate FDA’s efforts, Congress recognized the need to provide smaller operators with flexibility, and following with that intent, scalability limitations for smaller operators should be taken into consideration during the rulemaking process.”

NGA sought feedback from retailer and wholesaler members to identify challenges with the proposed rule that were then used to develop comments. In its comments, NGA outlined concerns in a number of areas, including the expanded scope and complexity of the proposed rule, the implementation phase-in period, and requirements of persons subject to the rule to produce an sortable electronic spreadsheet.

“NGA and our members are fully committed to working collaboratively with our industry partners and government to address ongoing concerns and developing best practice solutions going forward,” said Molly Pfaffenroth, NGA senior director of government relations.

Full text of NGA’s comments can be viewed here