3d • General discussion
Q&A
Hello! I hope this weekend was great for you all and that the start of the week has been productive. Happy Monday!
I’ve compiled 5 questions that I hear a lot from my clients and that you might benefit from too! If you have more add them to the comments and I will get them answered.
🌟 1. “How do I know if I need to register with the FDA?”
The short answer is: if you're manufacturing, processing, packing, or holding food for consumption in the United States, you most likely need to register with the FDA. This applies to both domestic and foreign facilities. However…there are some exemptions: farms that only grow and harvest raw agricultural commodities, and businesses that fall under the "very small business" threshold for certain rules may have modified requirements.
The bigger trigger most small CPG brands hit is the Food Safety Modernization Act (FSMA). Under FSMA, if your annual food sales exceed $1,000 in a given year and you sell to someone other than the final consumer (meaning you sell to a store, distributor, or farmers market reseller), you are likely required to register and comply with Preventive Controls regulations. Even if you sell directly to consumers at a farmers market, once you start scaling into retail or e-commerce, that registration clock starts ticking.
Registration is done through the FDA's Bioterrorism Act portal (you can find it at FDA.gov), it's free, and it must be renewed every two years during the October–December window of even-numbered years. Don't wait until a retailer asks for it. Get registered early because buyers, co-packers, and distributors will almost always ask for your FDA registration number before they'll work with you.
🌟 2. “Our inspector said we needed an SDS binder for our chemical area...what is that?”
SDS stands for Safety Data Sheet (previously called MSDS — Material Safety Data Sheet). An SDS binder is simply a physical or digital collection of safety documents for every chemical product used in your facility—sanitizers, degreasers, lubricants, pest control chemicals, cleaning agents, and food-grade detergents.
Each SDS sheet is provided by the manufacturer of that chemical and contains 16 standardized sections covering things like: what the chemical is, health hazards, safe handling and storage, what to do in case of a spill or exposure, and first aid measures. OSHA's Hazard Communication Standard (HazCom) requires that these be readily accessible to any employee who works with or around those chemicals.
For your binder, here's what to do practically:
- Contact every chemical supplier you use and request the SDS for each product (most are downloadable directly from the supplier's website)
- Organize them alphabetically or by area of use (sanitation, maintenance, pest control, etc.)
- Keep the binder in or directly adjacent to the chemical storage area — not in an office
- Train your employees on where it is and how to use it
- Update it any time you add a new chemical or switch brands
Inspectors love to see this binder well-organized and current. It's a quick win that shows your facility takes food safety and worker safety seriously.
🌟 3. “What is the best way to track inventory?”
For someone just starting out or at the farmers market level, the most important thing is to start with a system — any system — and be consistent. The businesses that struggle most with inventory aren't using the wrong software, they just have no process at all.
Here's how to think about it in stages:
Stage 1 (Starting Out): A well-organized spreadsheet with a simple FIFO (First In, First Out) tracking method works fine. Log your incoming raw materials with date received, lot number, quantity, and supplier. Log your outgoing finished goods the same way. This matters enormously if you ever have a recall — you need to know which batch of product used which lot of ingredients.
Stage 2 (Scaling Up): Once you're doing consistent volume, graduate to a dedicated inventory or food ERP tool. Options like Craftybase, Fishbowl, inFlow, or even QuickBooks with inventory tracking are popular in the small CPG space. They let you track raw materials, work-in-progress, and finished goods, and some can connect directly to your sales channels. (I am also creating my own web app ERP tool that I would have wanted to use when I was managing a manufacturing facility. Stay tuned!)
Stage 3 (Retail/Distribution Ready): At this point you'll want full lot traceability — meaning you can trace any finished product unit back to every ingredient lot used to make it. This is a FSMA requirement for most manufacturers and something every major retailer will ask about during a food safety audit.
Regardless of which stage you're at, always do physical counts on a regular cadence (weekly or monthly) and reconcile them against your records. Shrinkage, waste, and data entry errors add up fast.
🌟 4. “How do I source ingredients and packaging without having to rely on Sysco and Amazon?”
This is one of the most common pain points for emerging brands, and the good news is there are excellent alternatives, you just have to know where to look.
For Ingredients:
- Dot Foods is a redistributor that carries thousands of food ingredients and is specifically designed for smaller buyers who can't meet minimum orders from large distributors
- Specialty food distributors in your region often carry ingredients that Sysco doesn't — search for regional food ingredient distributors in your state
- Direct from manufacturers — once you know the brand or ingredient you need, go directly to the manufacturer's website and look for their "foodservice" or "industrial" sales contact. Many will sell direct once you hit modest minimums
- ThomasNet.com and Alibaba (for domestic suppliers) are directories where you can search for ingredient manufacturers by category
- Trade shows like the Fancy Food Show, SupplySide West, and IFT are goldmines for sourcing. You meet suppliers face to face and often get better pricing and relationships than any online search
For Packaging:
- Berlin Packaging, SKS Bottle, Uline, and TricorBraun are all solid options for small-to-mid volume buyers
- Alibaba is viable for packaging (bags, pouches, jars) but build in lead time and always order samples first
- Your local packaging distributor: most cities have regional packaging distributors who can source almost anything and often have lower minimums than national players
- Connecting with other small CPG brands in your area can also lead to co-buying arrangements where you split a minimum order and cut costs for both parties
The key mindset shift here is: build supplier relationships, not just transactions. A sales rep who knows your business will often find ways to accommodate smaller orders, offer better terms, and give you early notice on price changes or supply issues.
🌟 5. “Do I need to create my own written GMPs or is that more of a conceptual thing that people follow?”
You absolutely need written GMPs. This is not just a concept or a general mindset. Written Good Manufacturing Practices (GMPs) are a formal regulatory requirement under 21 CFR Part 117 for any facility subject to FSMA, and they are one of the first things any auditor, co-packer, or retail buyer will ask to see.
Think of your written GMPs as the rulebook for how your facility operates. They typically cover:
- Personnel hygiene — handwashing requirements, illness policies, hair and jewelry restrictions
- Facility and equipment maintenance — cleaning schedules, pest control, equipment calibration
- Sanitation procedures — how and how often surfaces, equipment, and floors are cleaned and sanitized
- Receiving and storage — how incoming ingredients are inspected, labeled, and stored
- Production controls — how you prevent contamination during manufacturing
- Allergen controls — especially critical if you handle multiple products with different allergens
Having these written down serves three critical purposes: it creates accountability (your employees know exactly what's expected), it creates consistency (the process doesn't change depending on who's working), and it creates evidence during an inspection or audit that your food safety program is real and operational, not just something you talk about.
You don't need to hire a consultant to write them from scratch. FDA's website has GMP guidance documents, and organizations like the Food Marketing Institute and Cornell's food science extension program have free templates. But you do need to customize them to your specific facility, products, and processes—a copy-paste generic GMP that doesn't reflect how your operation actually runs will raise red flags immediately with any experienced auditor.
If you have follow-ups or new questions add them below!
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