Every Manufacturer Marketing Alcohol Beverage Products in the U.S. Must Reregister
Under federal law, "food facilities" -- which include wineries, breweries, and distilleries that market their products in the United States -- are required to register with the U.S. Food and Drug Administration (FDA) and renew their food facility registrations this year during the period beginning on October 1, 2014 and ending on December 31, 2014. Because this registration obligation covers the entire food and beverage industry, facilities are advised to renew their registrations early in the three-month renewal period, i.e., NOW!
FDA has three guidance documents available to assist alcohol beverage producers and other food facilities with the registration process, including information on biennial registration renewal. These guidance documents, which are accessible online via the FDA’s Web site, are listed and linked below:
- The Guidance for Industry: What You Need to Know About the Registration of Food Facilities – Small Entity Compliance Guide was updated in 2012 to reflect FSMA amendments to the FD&C Act. This document contains information regarding (i) who is required to register and who may be exempt; (ii) how often facilities must register and renew registrations; (iii) when FDA may suspend a registration; and (iv) how facilities may submit their registrations and registration renewals to FDA.
- The Guidance for Industry: Questions and Answers Regarding Food Facility Registration (Fifth Edition) was updated in 2012 and contains helpful Frequently-Asked-Questions and answers regarding food facility registration. Updates to questions in this edition are based on FSMA amendments.
- The Guidance for Industry: Necessity of the Use of Food Product Categories in Food Facility Registration contains information regarding food-product categories included in the food facility registration form.
If you have any questions regarding your company’s obligation to register or reregister as a food facility with FDA, please contact GrayRobinson’s Alcohol Beverage and Food Law Department at (866) 322-5132 or beveragelaw@gray-robinson.com.
This article is published in the October 2014 issue of Fintech Focus. For more information, click here.