Food & Beverage Litigation Update l September 2020 #2 | Shook, Hardy & Bacon L.L.P.

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FDA Proposes Additional Traceability Requirements for “High Risk” Foods

The U.S. Food and Drug Administration (FDA) has released a proposed update to traceability recordkeeping requirements for foods considered “high risk” as sources of foodborne illness. The proposed rule would apply to entities that manufacture, process, pack or hold foods on the Food Traceability List and would require companies to “establish and maintain records containing information on critical tracking events in the supply chain for these designated foods, such as growing, shipping, receiving, creating, and transforming the foods.” The rule reflects the terms of a settlement FDA reached with the Center for Food Safety in a lawsuit intended to compel the agency to meet requirements set forth…

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