A summary of FSMA final rule to implement intentional adulteration requirements for human food.

• As promised, we have prepared a summary of FDA’s final rule to implement the intentional adulteration provisions of the FDA Food Safety Modernization Act (FSMA).

• Although the core components of the intentional adulteration requirements remain substantially similar to those in the proposed rule, FDA has revised and clarified the final rule in several key respects.  Of particular benefit to the food industry, FDA has extended the compliance date to 3 years after the effective date (i.e., July 26, 2019), as compared to the initial proposal of a 1 year compliance deadline.