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CDA Submits Comment Letter to FDA on FSMA Flexible Options

On July 15, 2026, CDA, in partnership with the Minnesota Wholesale Marketers Association (MWMA), submitted a formal comment letter to the U.S. Food and Drug Administration (FDA) responding to a series of questions that the agency posed to the industry about various methods, called flexible options, to trace food products under the Food Safety Modernization Act’s food traceability rule. The second addendum to the comment letter includes a joint CDA/MWMA memorandum explaining the issue of “eaches” and detailing an imprinting option to minimize the food tracing burden on wholesale distributors. Read the formal comment letter here.

About CDA

The Convenience Distribution Association (CDA) is the trade organization working on behalf of convenience products distributors in the United States. Its distributor members represent more than $110 billion in U.S. convenience product sales, serving a wide variety of small retail formats. Associate members include leading convenience product manufacturers, brokers, retailers, suppliers and others allied to the industry.

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CDA does not endorse any product or service that is advertised in CDA magazines or newsletters, displayed at CDA trade shows, or otherwise promoted by CDA members. CDA has not verified whether any tobacco or deemed tobacco product is authorized pursuant to current FDA rules and regulations. CDA shall not be liable for any purchase of, use by, or claim relating to any advertised product.

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