NFI Comments on FDA Traceability Recordkeeping Requirements
National Fisheries Institute
NFI's formal comments to the FDA on proposed food traceability recordkeeping requirements, addressing legal authority, product and facility exemptions, supply-chain traceability, implementation costs, and the practical needs of the global seafood industry.
Executive summary
The National Fisheries Institute submitted formal comments to the U.S. Food and Drug Administration on February 22, 2021, regarding proposed requirements for additional traceability records for certain foods under the Food Safety Modernization Act (FSMA) Section 204.
The submission examines how proposed traceability requirements could affect seafood businesses operating across complex domestic and international supply chains. NFI emphasizes the need for a practical, focused approach that strengthens the ability of industry and regulators to conduct efficient product tracebacks and recalls without requiring unnecessary transparency into commercially sensitive business relationships.
Key areas addressed in the submission include FSMA Section 204 legal authority, the Food Traceability List, exemptions for certain products and facilities, alignment with other traceability requirements, implementation and recordkeeping costs, international supply-chain considerations, and the operational complexity of seafood traceability.
NFI also calls for international outreach to ensure that traceability requirements can be implemented effectively across global seafood trading partners. The submission includes seafood supply-chain examples and an assessment of FDA's proposed supply-chain example to demonstrate the practical challenges businesses may face when implementing new recordkeeping requirements.