My facilities make food contact packaging. Our Corporate HQ does product testing and R&D and receives food from our customers in order to test the packaging. If there is a surplus, we occasionally give away the extra food, still sealed, to employees. In the past we have registered as an FDA facility due to this, on the basis that we're holding food that is consumed by the public. We fall under the exemption for supplier verification as an R&D facility except that we give the extra food away on occasion, maybe a few times per year. Has anyone else experienced a similar issue or gotten an exemption?
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