AIM North America Sends Letter to FDA in Response to IFPA Proposal to Allow TLC

AIM North America’s Food Supply Chain Work Group (subject matter experts of the design and application of automatic identification and data collection technologies), wrote to the FDA to express their collective concerns regarding the proposal to allow the calculation of Traceability Lot Codes (TLC) from business system data to comply with the FDA's FSMA 204 Food Traceability Rule.
 
While AIM NA understands the industry's challenges in achieving compliance, AIM NA believes this proposal undermines the rule's core objective: ensuring reliable and accurate traceability of food products throughout the supply chain. AIM NA strongly urges the FDA to reject this proposal and instead support initiatives that enhance the reliability and efficiency of data capturing processes. The attached document provides the rationale for our objections, and AIM NA request a meeting to elaborate on how data capture techniques, fostering global interoperability based on consensus-based standards, and promoting full chain transparency, can ensure that the food traceability system remains robust, transparent, and capable of protecting public health.