Earlier this month, AHPA (American Herbal Products Association) submitted comments to FDA on the proposed rule on traceability of certain foods.  Under the proposed rule, the first receiver of listed foods would be required to create a lot-specific traceability lot code for the food.  Finished foods containing ingredients from the FTL (Food Traceability List) would be subject to the same traceability requirements.  The AHPA, along with other trade associations, has requested that FDA consider issuing a supplemental rule to simplify the requirements.  For example, one proposed entry is for “Herbs (fresh)” which includes parsley, cilantro, and basil.  The AHPA believes that the risk model outlined by FDA does not support the need for such detailed traceability for all herbs, particularly those used in dietary supplements which have a low occurrence of adversity partly due to the processing that occurs.  AHPA requested that the FTL be amended to include only fresh culinary herbs that typically undergo no processing.

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Posted on 12 April 2021