NCBFAA Touts Role of Brokers in Applying Blockchain Tech to Food Safety Supply Chain

The Food and Drug Administration should harness blockchain, artificial intelligence and other emerging technologies to address food safety issues in quickly evolving supply chains, and customs brokers will play a central role in facilitating adoption and the correct use of these new technologies by smaller and medium-sized operations, the National Customs Brokers & Forwarders Association of America said in comments recently submitted to FDA.

The FDA had sought the comments as part of its effort to develop a “Blueprint for a New Era of Smarter Food Safety,” which included a public meeting held in October. “We are pleased that FDA has initiated this dialogue with stakeholders as you shape the agency’s vision for food safety in a rapidly changing trade landscape,” the NCBFAA said in its written comments.

The number of importers has exploded with the rise of e-commerce in recent years, and “food supply chains are about as diverse and complex as you can find,” the trade group said. “New and emerging technologies, such as blockchain, the Internet of Things and Artificial Intelligence, offer promising -- perhaps revolutionary -- ways to address these challenges,” it said. “Customs brokers will inevitably be key players in FDA’s efforts to harness blockchain to enhance the safety of imported foods.”

The food supply chain is a “vast network” with many smaller companies that, unlike larger operations, may not have the “wherewithal or inclination to participate in blockchain,” the NCBFAA said. Brokers can facilitate their clients’ participation by adding information to the blockchain on their behalf, as well as by helping to collect that data and ensuring that it is accurate. “With processes already in place to identify the parties and other elements of the shipment, we can add value to the blockchain consensus mechanism by validating important details of the transaction,” the trade group said.

But while an important tool, blockchain is not a “silver bullet,” and it should work together with existing systems like ACE and the Import Trade Auxiliary Communication System (ITACS) rather than replace them, the NCBFAA said. “Achieving a smooth interaction of blockchain with current processes will be a critical focus for both FDA and the trade,” and “customs brokers will be an important link as blockchain and ACE intersect, helping to assure smooth synergy between the two.”

CBP and FDA should work hand-in-hand to avoid duplication and inconsistencies, and other partner government agencies (PGAs) should be invited to participate, the NCBFAA said. “The International Trade Data System (ITDS) single-window model should be the model for future agency coordination of blockchain efforts,” it said.

The NCBFAA also told FDA that simpler technology solutions, like specialized apps, should also be explored “to provide streamlined short-cuts to routine, manual tasks at ports of entry.” Artificial intelligence also has the potential to “sharpen and expand FDA’s predictive analytics.” But good data is critical, and FDA must not “overlook the fundamental building blocks to ensure good data, such as enhancing the agency’s Product Code Builder and providing a mechanism to provide advisory rulings to importers/filers when necessary to clarify the proper product codes,” the NCBFAA said. FDA should also “enforce the requirement that low-value food and other FDA-regulated products utilize Entry Type 86, allowing the FDA to capture the data it needs” on low-value shipments, it said.