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USFDA Clarification Memorandum on Food Traceability List on January 12, 2021

it.assistant@ipcnet.org 13 Jan 2021 6957

The United States Food and Drug Administration (USFDA) via memorandum dated January 12, 2021, has released an update on the Food Traceability List for "Requirement for Additional Traceability Records for Certain Foods" Proposed Rule-Clarified Language. Previously, the USFDA has published a proposed rule for Requirements for Additional Traceability Records for Certain Foods on September 23, 2020.

The core of the proposed rule is a requirement for those who manufacture, process, pack or hold foods on the Food Traceability List which is tentatively identified by utilizing risk-ranking model, to establish and maintain record containing Key Data Element associated with different Critical Tracking Events. Furthermore, the Food Traceability List includes specific listed food as well as any food containing the listed food as ingredients. The proposed rule stipulates the following Food Traceability List:

Foods Description
Cheeses, other than hard cheeses Includes all cheeses made with either pasteurized or unpasteurized milk, other than hard cheeses. Includes soft ripened/semi-soft cheeses (e.g., brie, camembert, feta, mozzarella, taleggio, blue, brick, fontina, monterey jack, and muenster) and soft unripened/fresh soft cheeses (e.g., cottage, chevre/goat, cream, mascarpone, ricotta, queso blanco, queso fresco, queso de crema, and queso de puna).
Shell eggs Shell egg means the egg of the domesticated chicken
Nut butter Includes all types of tree nut and peanut butters; does not include soy or seed butters
Cucumbers (fresh) Includes all varieties of cucumbers
Herbs (fresh) Includes all types of herbs, such as parsley, cilantro, basil, etc.
Leafy greens (fresh), including fresh-cut leafy greens Includes all types of leafy greens, such as lettuce, (e.g., iceberg, leaf and Romaine lettuces), kale, chicory, watercress, chard, arugula, spinach, pak choi, sorrel, endive, etc.
Melons (fresh) Includes all types of melons, such as cantaloupe, honeydew, watermelon, etc.
Peppers (fresh) Includes all varieties of peppers
Sprouts (fresh) Includes all varieties of sprouts
Tomatoes (fresh) Includes all varieties of tomatoes
Tropical tree fruits (fresh) Includes all types of tropical tree fruit, such as mango, papaya, mamey, guava, lychee, jackfruit, starfruit, etc.
Fruits and Vegetables (fresh-cut) Includes all types of fresh-cut fruits and vegetables
Finfish, including smoked finfish Includes all finfish species, such as cod, haddock, Alaska pollock, tuna, mahi mahi, mackerel, grouper, barracuda, salmon, etc.; except does not include siluriformes fish, such as catfish [1]
Crustaceans Includes all crustacean species, such as shrimp, crab, lobster, crayfish, etc.
Mollusks, bivalves Includes all species of bivalve mollusks, such as oysters, clams, mussels, etc.; does not include scallop adductor muscle.
Ready-to-eat deli salads Includes all types of ready-to-eat deli salads, such as egg salad, potato salad, pasta salad, seafood salad, etc.; does not include meat salads

The memorandum dated January 12, 2021, updated the table of Food Traceability List by adding to the description of certain foods. The additional description mentioned is the classification of "fresh" on some food. Thus, confirming commodities such dried herbs and dried peppers, including black pepper and capsicums will not be subjected to the requirements of the aforementioned proposed rule. Furthermore, the American Spices Trade Associations is currently working with the Government Relations Committee to comment on the need for the new clarification of "fresh" in relation to the aforementioned Proposed Rule.

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