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  5. FSMA Inflation Adjusted Cut Offs
  1. Food Safety Modernization Act (FSMA)

FSMA Inflation Adjusted Cut Offs

Implicit Price Deflators for Gross Domestic Product (GDP)

Several FSMA rules have provisions in which a value is adjusted for inflation and averaged over 3 years. We provide the values based on Price Deflators for Gross Domestic Product (GDP) and the average for the most recent 3 years for the applicable rules below. The GDP deflator is not a static number, and changes monthly. We intend to update the values at the beginning of April each year.

NOTE: Beginning in 2024, the U.S. Bureau of Economic Analysis (BEA) uses 2017=100 for estimating the GDP deflator instead of 2012=100. We have updated all the values in the tables on this page to reflect the changes to the GDP deflator. BEA current standard practice is to update the base for GDP deflator every 5 years; FDA will update in unison and provide that update here.

 20212022202320242025
GDP Deflator110.186118.023122.39125.428128.979

If you choose to use the information below to determine whether your facility, farm, or other operation (depending on the relevant FSMA rule) had average annual sales/revenue below the most recent adjusted cut-off, you would:

  1. Determine your annual sales and/or revenue information (depending on the FSMA rule) for each of these years: 2023, 2024, and 2025;
  2. Calculate your average annual sales/revenue for those three years;
  3. Compare your three-year average to the value posted in the column titled “Average 3 Year Value for 2023 – 2025.”

Qualified Facility: Definition 1: Very Small Business - a facility averaging less than $1 million (adjusted for inflation) in annual sales per year during the 3-year period preceding the applicable calendar year in sales of human food plus the market value of human food manufactured, processed, packed, or held without sale.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$1,000,000$1,204,469$1,290,137$1,337,873$1,371,083$1,409,899$1,372,952

Qualified Facility: Definition 2: Average annual monetary value of all food sold during the 3-year period preceding the applicable calendar year was less than $500,000, adjusted for inflation and sales to qualified end-users during such period exceeded the average annual monetary value of the food sold by such facility to all other purchasers.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$500,000$602,234$645,068$668,937$685,541$704,950$686,476

Qualified Facility: Definition 1: Very Small Business - a facility averaging less than $2.5 million (adjusted for inflation) in annual sales per year during the 3-year period preceding the applicable calendar year in sales of animal food plus the market value of animal food manufactured, processed, packed, or held without sale.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$2,500,000$3,011,172$3,225,342$3,344,684$3,427,706$3,524,748$3,432,379

Qualified Facility: Definition 2: Average annual monetary value of all food sold during the 3-year period preceding the applicable calendar year was less than $500,000, adjusted for inflation, and sales to qualified end-users during such period exceeded the average annual monetary value of the food sold by such facility to all other purchasers.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$500,000$602,234$645,068$668,937$685,541$704,950$686,476

Qualified Exemption: A farm is eligible for a qualified exemption if the average annual monetary value of all food sold during the 3-year period preceding the applicable calendar year was less than $500,000, adjusted for inflation, and sales to qualified end-users during such period exceeded the average annual monetary value of the food sold by such farm to all other buyers.

NOTE:  In May 2020, FDA issued guidance announcing flexibility in the eligibility criteria for the qualified exemption from the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption Regulation due to disruptions to the supply chain during the COVID-19 public health emergency. This temporary policy remained in effect until Nov. 7, 2023. In April 2023, FDA issued guidance to help explain how farms may transition from the temporary policy back to the usual qualified exempt criteria in the Produce Safety Rule. We expect that in 2027, farms should have the necessary data to be able to transition back to averaging sales to qualified end-users over relevant three-year periods.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$500,000$602,234$645,068$668,937$685,541$704,950$686,476

Not covered farm: A farm or farm mixed-type facility with an average annual monetary value of produce sold during the previous 3-year period of less than $25,000 (on a rolling basis).

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$25,000$30,112$32,253$33,447$34,277$35,247$34,324

Very Small Importer: Definition 1 for Human Food – an importer (including any subsidiaries and affiliates) averaging less than $1 million per year, adjusted for inflation, during the 3-year period preceding the applicable calendar year in sales of human food combined with the U.S. market value of human food imported, manufactured, processed, packed, or held without sale.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$1,000,000$1,204,469$1,290,137$1,337,083$1,371,083$1,409,899$1,372,952

Very Small Importer: Definition 2 for Animal Food - an importer (including any subsidiaries and affiliates) averaging less than $2.5 million per year, adjusted for inflation, during the 3-year period preceding the applicable calendar year in sales of animal food combined with the U.S. market value of animal food imported, manufactured, processed, packed, or held without sale.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$2,500,000$3,011,172$3,225,342$3,344,684$3,427,706$3,524,748$3,432,379

Non-covered business: Shipper, loader, receiver, or carrier engaged in transportation operations that has less than $500,000, as adjusted for inflation, in average annual revenues, calculated on a rolling basis, during the 3-year period preceding the applicable calendar year.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$500,000$602,234$645,068$668,937$685,541$704,950$686,476

Very Small business: A business (including any subsidiaries and affiliates) averaging less than $10,000,000, adjusted for inflation, per year, during the 3-year period preceding the applicable calendar year in sales of human food plus the market value of human food manufactured, processed, packed, or held without sale.

Baseline Value for Cut-offs (2011)Value in 2021Value in 2022Value in 2023Value in 2024Value in 2025Average 3 Year Value for 2023 - 2025
$10,000,000$12,044,687$12,901,367$13,378,734$13,710,825$14,098,993$13,729,518

On November 21, 2022, FDA published the Food Traceability Final Rule, which includes various provisions in which a value is adjusted for inflation and averaged on a rolling basis over 3 years. We intend to post relevant values adjusted for inflation in future updates to this webpage.

The original compliance date for all persons subject to the recordkeeping requirements of the Food Traceability Rule was January 20, 2026. The FDA proposed to extend the compliance date for the rule by 30 months to July 20, 2028. Subsequently, the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act of 2026 (the Continuing Appropriations Act) directed FDA not to enforce the Food Traceability Rule prior to that same date of July 20, 2028. The FDA intends to comply with this Congressional directive. 

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