Tuesday, October 9, 2012

Registering Wineries as "Food Facilities"

Edit: The registration is now active.  Please register.


By Cary M. Greene

It’s time to try to register your winery with FDA.

As WineAmerica announced last July when the Food Safety Modernization Act became law, wineries are required to register as “food facilities” with the Food & Drug Administration (“FDA”) “[d]uring the period beginning on October 1 and ending on December 31 of each even-numbered year.”  See 21 U.S.C. § 350d(a)(3) (emphasis added).

That would mean wineries are supposed to renew their registration with FDA over the next three months.

Ordinarily, FDA’s website is user friendly and online registration fairly straightforward.  FDA even has a Help Desk line, 800-216-7331, in case you run into trouble.  Currently, however, the site where wineries would register contains a notice:

Biennial Registration Renewal for Food Facilities will not be available on October 1, 2012.  We therefore will not be accepting food facility registration renewals at this time.  Please check FDA’s website at http://www.access.fda.gov at a later date or sign up for FSMA updates to be informed when it becomes available.  Additional information regarding Registration Renewal may be found on the FSMA Registration page.

We’ve checked with FDA, and they’re saying that wineries don’t need to submit their renewal registrations for 2012 yet.  This doesn’t mean you’re released of your obligation to register this year, it just means you need to check periodically on FDA’s registration page, or the WineAmerica blog, until registration goes live.

Edit:  The registration is now active.