· 2 min read · FoodChainAPI editorial
Fresh Herbs and Dill: Separate an FTL Match from an Exemption
Fresh herbs illustrate why a category match and an exemption review must be separate. FDA's Food Traceability List explains that dill is exempt under the rule's provision for produce listed as rarely consumed raw in the Produce Safety Rule.
Resolve the herb and its form
A supplier description such as 'herb assortment' is not sufficient. Obtain the specific herbs and whether they are supplied fresh, dried, frozen, or in another form. A broad reference to the fresh-herbs category should not substitute for checking the actual product.
Read the notes attached to FDA's list, not just the category heading. The dill example is especially useful for software testing because a food can appear related to a category yet have a separate exemption basis. Keep those facts in separate fields so a category candidate does not override a reviewed exception.
Handle an assortment carefully
For a pack containing several herbs, identify the components and relevant forms. Do not apply one ingredient's exemption to every other ingredient in the pack. Retain the specification and assess the finished product using the FDA ingredient guidance where applicable.
If your supplier changes an assortment without changing the catalog name, the old review can become stale. Make component changes a trigger for reassessment. A stable SKU is not proof that its ingredients and regulatory context have remained unchanged.
- Name each herb rather than using an assortment label.
- Record the supplied form.
- Read category notes and applicable exemption provisions.
- Keep a documented reason for the final decision.
- Review changed assortments and specifications.
A regression test for your integration
Run a dill query through FoodChainAPI and inspect the candidate results, then compare them with FDA's current guidance. The current name matcher may surface broad fresh-herb candidates; it does not evaluate every legal exemption. Your application must preserve the review step.
Test that the interface displays 'candidate category' and an unresolved or reviewed status, instead of automatically issuing a compliance verdict. Include both a supported category match and an exemption review in your acceptance cases.
Put the product review into practice
Start with a candidate category in the free FTL lookup. Check product form and exemptions against FDA sources, then save the evidence behind your decision.
API referenceUse in Chrome, ChatGPT, or ClaudeProduct review walkthrough
Sources and scope
FDA sources checked October 4, 2026. Workflow suggestions are implementation guidance; category matches do not establish exemption or compliance status. Check the current FDA requirements for your product and activities.