K&H publishes summary of FSMA final rule to implement intentional adulteration requirements for human food.

• As promised, Keller and Heckman LLP has prepared a summary of FDA’s final rule to implement the intentional adulteration provisions of the FDA Food Safety Modernization Act (FSMA).
• Click here for our summary of the rule and its implications for the food industry.
• Although the core components of the intentional adulteration requirements remain substantially similar to those in the proposed rule, FDA has revised and clarified the final rule in several key respects.  Of particular benefit to the food industry, FDA has extended the compliance date to 3 years after the effective date (i.e., July 26, 2019), as compared to the initial proposal of a 1 year compliance deadline.

We will continue to monitor and report on FDA’s activities to implement this rule and other FSMA related activities.  Please email fooddrug@khlaw.com and let us know if you have any questions or if you would like to discuss the impact of the final rule or any other FSMA related issues in the meantime.