What's everyone doing about FDA registration?

[heus]

I see in the Maple News that registration is mandatory by next year some time. Being someone who sells most of my syrup wholesale, I will be required to be inspected. I am not sure what I am going to do about this. If I have to invest a ton into washable walls, worker bathrooms, etc I may just downsize and sell mostly retail. Can someone tell me what the inspections will entail? I am in Ohio.

[maple maniac65]

Well that is a very good question. I would love to see a checklist posted that defines just that IN SIMPLE ENGLISH. I tried to register but I think I need a 5th grader to decipher the form so I can find that one box that says I am not a threat.

[buckeye gold]

heus, Do you usually attend Ohio Maple days in January. Dan Milo with the Dept. of Ag food safety usually goes over all that and updates everyone on what is new. They are holding one at a new site in Geauga County this year. SOmewhere I have Dan's e-mail, PM me if you want it and I'll see if I can find it.

[amaranth farm]

Radio Silence.

[maple maniac65]

McClure in Littleton required proof of registration to sell to them. I am lead to believe all packers are going to require proof of registration

[wiam]

McClure in Littleton required proof of registration to sell to them. I am lead to believe all packers are going to require proof of registration

Maple Grove checks for registration.

[Bucket Head]

Folks will have to register to sell to a packer even though they may not sell over half their crop wholesale?

There does seem to be an awful lot of confusion still about this FDA registration. The wholesale/retail, small producer/large producer wording in recent publications has not helped. Recent conversations prove many producers do not know "where they are supposed to stand" with this. I agree that a short list of much simplified and clearly defined set of rules regarding this would be great thing for all. And reports of daunting attempts at the online registration doesn't exactly encourage folks to register either.

[amaranth farm]

Radio Silence.

[wiam]

Not by law. If a packer decides to hold your feet to the fire, then you have a choice. Find more ways to sell "privately", educate your packer, or find a packer that does not misinterpret the law. Bottom line is that if you sell less than 50% of your total crop to packers, you are not bound by the law to register.

Packer is not necessarily misinterpreting the law. They get to pick what rules they want to follow when buying syrup. Might be their own standards or who they sell to down the line.

[DrTimPerkins]

They get to pick what rules they want to follow when buying syrup. Might be their own standards or who they sell to down the line.

That pretty much sums it up. With the current oversupply of syrup, and the buyers of syrup requiring more documentation from the packers, they are simply applying the same standards to all the folks they buy syrup from. Your choice is to comply with their rules and sell to them, or don't and sell to someone else (if you can find someone who uses different rules).

[johnallin]

It's my understanding that the FDA registration is more about tracing a food products source in the event of tainted product. You agree to supply contact information and location(s).

It is not an endorsement by the FDA, the operator agrees to allow inspection if requested. I filled one out in '15 and received a reg number. I understood that to imply that if I sold product, I was willing to have someone look over what we do or at least be prepared to have "visitors" if someone got ill due to our syrup...

I'm not a fan of bigger government, or more regulation. But I do like the fact that in this country we have standards established to ensure that our grandkid's formula isn't produced in a re-purposed heating oil tank! Bottom line is that if you're producing a product for human consumption - it's either made right or it isn't. If I need surgery, it's good to know that the Dr. has spent the time and resources to learn his craft...Any thing less is akin to the fox guarding the hen house.

Not trying to stir things up, but the maple industry has lots of professionals who have invested heavily in sanitary best practice equipment and methods who compete with semi-pro hobbyists. Selling farm gate or at the sugar house is one thing, selling mainstream opens up another can of worms. My 2¢.

[hookhill]

Agreed, safe food is important. Regulations, low bulk prices, expensive equipment....Maybe its time to go back to 50 buckets and a beer.

[heus]

What about those that just sell sap? Will there be any registration requirement for them?

[johnallin]

Since sap is not the final product, I would think not.

[maple flats]

I registered in late 2015, but since I sell most of my syrup retail I haven't needed it yet. As things change, for what Commercial I sell, I may need it, I retail everything else.

[markcasper]

I registered in late 2015, but since I sell most of my syrup retail I haven't needed it yet. As things change, for what Commercial I sell, I may need it, I retail everything else.

I am not sure in your state, but in Wisco., if you sell to one store you must have a food processing license, and therefore would have to be registered with the FDA. If you sell all of it direct to the consumer, then you wouldn't have to.

[DrTimPerkins]

You only need to register if more than half of your total output is bulk sales to a packer. Do you?

Actually, I believe you are referring to the exemption of a retail establishment. This means that your primary business is retail sales, and that you are selling half or more of your total product DIRECT to consumers (farm gate, mail order, CSA, farmer's market). Wholesale doesn't count as DIRECT sales.

[prairietapper]

It's my understanding that the FDA registration is more about tracing a food products source in the event of tainted product. You agree to supply contact information and location(s).

It is not an endorsement by the FDA, the operator agrees to allow inspection if requested. I filled one out in '15 and received a reg number. I understood that to imply that if I sold product, I was willing to have someone look over what we do or at least be prepared to have "visitors" if someone got ill due to our syrup...

I'm not a fan of bigger government, or more regulation. But I do like the fact that in this country we have standards established to ensure that our grandkid's formula isn't produced in a re-purposed heating oil tank! Bottom line is that if you're producing a product for human consumption - it's either made right or it isn't. If I need surgery, it's good to know that the Dr. has spent the time and resources to learn his craft...Any thing less is akin to the fox guarding the hen house.

Not trying to stir things up, but the maple industry has lots of professionals who have invested heavily in sanitary best practice equipment and methods who compete with semi-pro hobbyists. Selling farm gate or at the sugar house is one thing, selling mainstream opens up another can of worms. My 2¢.

I have seen what I feel is Govt over reach many times. and yet I agree with you on this one :)