Well a few years ago when all this registration crap was being debated we were all told we had to register if we made syrup, period. If you were small or hobby they'd probably never bother you. Yeah, I'm gullible, but not that gullible. Then we were told hobby or small producers who didn't wholesale were not required to register. So I registered then unregistered and thought, "ok I don't have to worry about them bothering me".
Yesterday, the phone rang and a guy asked my name and if I produced Maple syrup. He identified himself as a FDA agent and had some questions and would be scheduling an inspection. Remember I canceled my registration 2 years ago. Turns out they still have your name and address. He was very nice and considerate. He asked me a series of questions about how I sold my syrup, what percentage went where and how much I made. After about a half hour on the phone he said he would not be scheduling an inspection, because I did not need to be a registered facility. Here are the reasons he gave me that made him determine that. I do not sell out of state and I do not sell bulk or wholesale. I told him I had heard that if less then 50% of total sells were wholesale then a producer didn't need to be registered and he replied generally yes. However, if you sell across state lines you need to register. So in the end he said they were in the process of determining who operated facilities that need registered and who doesn't. He said they in fact were eliminating a lot of producers as exempt. My guess is if you wholesale a lot (even less then half, but a large volume) and you sell across state lines they want you registered and they will be coming to see you.
I thought I'd share this, since there has been a lot of discussions on registration