Hello,
We are currently registered with the FDA for repacking frozen foods, food storage and distribution. The company structure is changing this year; I will try my best to explain below the changes and am seeking advice on how to appropriately change certificates without duplicating, i.e. 2 SQF certs/audits per year, etc.
- Company A the current FDA registration holder (as mentioned above)
- Company B is purchasing Company A's repacking operation*
- Company A will still continue to store is distribute foods
- Company C is listed currently on our FDA registration as a 'DBA' and acts as an umbrella company that allows us to share resources between the other small companies.
- All companies operate within 1 address/location.
*Company B is at times a competition packer for other repack customers; ownership has told me that we have to be able to pack both for Company B as well as any competitor companies that may seek repack in future (no guaranteed business for 2023 yet.)
In order to maintain other certificate programs; SQF, USDA Organic and not duplicate programs for Company A and B; I've consulted with our SQF CB for guidance. She suggested that if we register Company C with FDA and list Company A and B as DBA we could have our certificate encompass all as long as it matches the FDA registration.
I also consulted with the FDA and did not gain much help; I was advised that I would have to cancel our current FDA registration and re-register, but that it was up to me if I chose to do so. I also asked if Company C does not own Co A&B if that would impact in any way, they could not answer.
Has anyone else had to deal with something similar to this? Do you think I am on the right track for proper registration? I am trying my best to ensure proper coverage for all variables.
Thank you!
