FDA Food Facility Registration

We have a warehouse that stores packets of salt & pepper for use in a serving package of plastic dinnerware and napkins. No processing is performed. Is there a way around having the warehouse registered as a Food Facility?

We have a warehouse that stores packets of salt & pepper for use in a serving package of plastic dinnerware and napkins. No processing is performed. Is there a way around having the warehouse registered as a Food Facility?

From the FDA:

At this time, the same types of food facilities that were required to register with FDA under section 415 of the FD&C Act before FSMA are required to register with FDA and renew such registrations. Those facilities are domestic and foreign facilities that manufacture, process, pack, or hold food for human or animal consumption in the United States. Section 103© of FSMA directs FDA to conduct a rulemaking to “clarify the activities that are included as part of the definition of the term ‘facility’ under such section 415 [of the FD&C Act].” The rule to clarify activities that are included as part of the definition of the term “facility” will be proposed as part of the rulemaking for the preventive controls regulation, as provided by section 103© of FSMA.

I would say the short answer is NO.

Marshall