The Food Safety Modernization Act (FSMA) requires all food facilities (including most breweries) to register with the Food and Drug Administration (FDA) and complete a biennial renewal. This renewal period runs from October 1 – December 31 of even-numbered years. There is no fee for renewal, but failure to register is a prohibited act under the Food, Drug, and Cosmetic Act (FD&C Act). The FDA has developed a renewal overview and a step-by-step guide to facilitate compliance.
New in 2020, breweries are required to provide a Unique Facility Identifier (UFI) during registration and renewals. This additional piece of information will be required for submissions beginning in October 2020. FDA guidance documents published to date state that the only UFI format currently accepted by the FDA is the Data Universal Numbering System (D-U-N-S©). This is a service administered by a private firm, Dun and Bradstreet, and is provided free of charge. If the FDA decides to accept other UFI formats, it will update its guidance accordingly.
All breweries will need to apply for a UFI in time for their renewal and should pay close attention to the format requirements. Securing a UFI prior to applying for the FDA registration renewal will facilitate the process.