Clarification on FTR Compliance for Co-Packed Cheese at a USDA Facility

Clarification on FTR Compliance for Co-Packed Cheese at a USDA Facility

I recently joined my company and was contacted by one of our distribution centers regarding their efforts to comply with the FDA's Food Traceability Rule (FTR). Historically, the company marked itself as exempt due to being a USDA-regulated site. However, upon further investigation, I found that we have cheese co-packed with our Name attached (sliced American and Pepper Jack cheese) and I believe these products fall under the FTR requirements.

Does anyone have experience with how the FTR applies to a company like ours, which acts as a middleman in the supply chain? Specifically:

• Are we required to maintain FTR-compliant traceability records for co-packed products?
• How do these requirements differ for Pepper Jack (semi-soft cheese) versus American (processed cheese)?
• What steps should we take to ensure compliance while working as a USDA site?

Any insights or shared experiences would be greatly appreciated!