Jump to content

  • Quick Navigation
Photo

FDA registration requirements

Share this

  • You cannot start a new topic
  • Please log in to reply
2 replies to this topic
- - - - -

leet222

    Grade - Active

  • IFSQN Associate
  • 22 posts
  • 1 thanks
0
Neutral

  • United States
    United States
  • Gender:Male

Posted 08 August 2013 - 03:54 PM

I am a producer of food packaging.  I have been asked by a customer to take in bulk pre-packaged food and place it into my cartons.  I may have to hold it for a period of time in controlled conditions.  I do not, at any time, open any of the pre-packaged items...do not touch or expose the food itself.  I would then ship the cartons back to the customer.  Would I be required to register with the FDA?  Section 9.10 of the Food Defense Guidance for Industry would imply that I do not, as I am not "placing food in a container that directly contacts the food".  However, Section 17.2 implies that I have to because I am "holding" it.  It does, however, only directly identifies "produce". 

 

Comments?   Thanks!



JamieLynn

    Grade - Active

  • IFSQN Associate
  • 21 posts
  • 2 thanks
3
Neutral

  • United States
    United States

Posted 22 August 2013 - 06:30 PM

Are you labeling your cartons?



leet222

    Grade - Active

  • IFSQN Associate
  • 22 posts
  • 1 thanks
0
Neutral

  • United States
    United States
  • Gender:Male

Posted 04 September 2013 - 02:51 PM

I print and process a cardboard container...then insert a plastic form and the prepackaged food item inside the container.  Then I place a number of the assembled containers in a bulk carton for shipment to a customer.





Share this

0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users