Impact of FDA’s traceability rule on eggs is uncertain

The Food and Drug Administration’s (FDA) final rule for food traceability looks complex, however, it may not affect the egg industry as significantly as it seems.

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A group of Brown hens eggs on a white background
A group of Brown hens eggs on a white background
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The Food and Drug Administration’s (FDA) final rule for food traceability looks complex, however, it may not affect the egg industry as significantly as it seems.

While additional clarity is needed from the FDA before the egg industry can confidently act, it appears that many of the processes the new rule will enforce are practices that most egg producers already use, Oscar Garrison, UEP Senior Vice President of Food Safety, explained at the United Egg Producers’ (UEP) January 2023 Committee Meetings, held in conjunction with the 2023 International Production & Processing Expo (IPPE).

Garrison added that UEP plans to formulate a set of questions for the FDA to gain the additional insight needed for the egg industry to ensure compliance to the new requirements.

According to the FDA, the new rule will allow for rapid identification and removal of potentially contaminated food from the market, which will result in fewer foodborne illnesses or deaths. The FDA hopes the rule will standardize food traceability data across sectors and allow for product to be tracked more quickly.

The rule covers foreign and domestic entities and will go into effect on January 20, 2026.

Details of the rule

Foods that fall under the rule’s requirements are found on the FDA’s Food Traceability List (FTL). The FTL includes fresh cut fruits and vegetables, shell eggs, nut butters, fresh vegetables, ready-to-eat deli salads, cheeses and seafood products.

To comply with the rule, companies that manufacture, process, pack or hold food on the FTL must maintain records that include Key Data Elements (KDEs) that are related to Critical Tracking Events (CTEs).

According to Chris Waldrop, FDA Senior Health Scientist, CTEs are defined as key places that producers must track traceability data at in the process and KDEs include specific data points or required records that are dependent on the CTE. For example, if the CTE is a distributor, the KDEs comprise data from receiving and shipping areas.

The rule requires that covered farms, retail establishments or restaurants must be able to provide traceability information to the FDA within 24 hours, or a reasonable time the FDA agrees to.

Waldrop added that FDA has not decided the best approach for conducting inspections or enforcing the rule but is currently developing a compliance strategy.

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