Date: March 4, 2024
Traceability has changed the food supply chain industry forever. It threatens every process and introduces legal pressures that you never saw coming.
What are major retailers, wholesalers and distributors – including Kroger – doing in response? They’re leaning in.
If you want to comply, you need to join us for this URGENT discussion with Shawn Stevens, food industry lawyer and founder of Food Industry Counsel, LLC.
Food Safety Consultant and Lawyer
Founder, Food Industry Counsel
Watch the key points:
Risk and responsibility can’t be pushed onto the wholesaler from the retailer; each party has a legal obligation under the law and a duty to the consumer.
The deadline for enforcement is not going to change and the deadline date will not matter if there’s an outbreak as it will be addressed under current law.
FDA will begin every investigation with the retailer, therefore the retailer must have a robust traceability plan and recordkeeping.
Retailers are responsible to require their suppliers to do traceability; if products are purchased from a supplier who declines to do traceability, then the retailer assumes legal risk.
FDA has at its disposal, remedies that range from a public warning letter to suspension of a facility registration and criminal referral.
The risk of not tracing a product that has a FSMA 204 ingredient (think peanut butter) is high enough that retailers and wholesalers are better off tracing all food products.
Developing a traceability plan and implementing a traceability solution takes a long time. Getting started now is important.
