The Food Safety Modernization Act (FSMA) is a comprehensive overhaul of the U.S. food safety regulatory framework. Two of the most challenging issues faced by the global
produce industry supply web are what specific FSMA rules must a business comply with
and when must a business comply.
The purpose of this document from United Fresh is to explain why compliance dates are complicated (especially as related to the Foreign Supplier Verification Program), and why it is not possible to demonstrate compliance with the Produce Safety Rule prior to the regulatory compliance date due to FDA’s acknowledgement of potential changes to some provisions. It also addresses changes in FDA’s facility registration requirements.
FSMA Implementing Regulation Compliance Dates
A comprehensive list of FSMA compliance dates by implementing regulations can be found
FSMA compliance dates for produce businesses vary significantly based on:
(1) specific implementing regulation covering an enterprise (e.g. Produce Safety Rule versus Preventive Control for Human Foods Rule),
(2) enterprise size (e.g. small versus very small businesses)
(3) specific provisions of an implementing regulation (e.g. ag water provisions of the Produce Safety Rule)
(4) specific enterprise activities (e.g. facilities solely packing or holding Raw Agricultural
In August 2016 FDA announced compliance date extensions for a number of FSMA final rules. FDA has delayed the compliance date for FDA registered food facilities solely packing and holding Raw Agricultural Commodities (RACs) to comply with the Preventive Controls for Human Foods rule until January 26, 2018.
For more on FSMA compliance dates and registration, click here.