On August 20, 2018, the U.S. Food and Drug Administration (FDA) issued a supplemental draft guidance for the industry regarding food facility registration.
The supplement answers questions regarding scenarios involving multiple entities using shared space:
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Who should register if a manufacturer leases the building where it manufactures food?
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Which entity should register if a manufacturer stores food in a self-storage warehouse?
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Who should register when multiple manufacturers use a communal kitchen?
According to FDA, “…guidances describe our current thinking on a topic and should be viewed only as recommendations, unless specific regulatory or statutory requirements are cited,” and “do not establish legally enforceable responsibilities.”
The guidance document may be downloaded here:
https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/ucm615521.htm