FDA Source
Source: FDA.gov
How the Transformation CTE creates TLC obligations when milk becomes soft cheese.

FDA FSMA Supply Chain Example, Soft Cheese (November 2022)

– Dairy Farm: Milk is not on the FTL. The farm is not covered for raw milk. KDE obligations begin when soft cheese is manufactured.
– Cheese Manufacturer, Transformation CTE: Milk (non-FTL) is transformed into soft cheese (FTL). KDEs include: location of transformation, new product description, quantity, date of transformation, and TLC assigned to the new cheese lot. The manufacturer is the TLC Source.
– Cheese Manufacturer, Shipping CTE: Must transmit TLC, TLC source, product description (GTIN preferred), quantity, ship date, and name/location of immediate subsequent recipient.
– Distribution Center, Receiving & Shipping CTEs: Receives TLC from manufacturer and passes it forward to retail with all required shipping KDEs.
– Retail, Receiving CTE: Must maintain receiving KDEs for the soft cheese, linked to the manufacturer’s TLC.
How Commport Automates This: Soft cheese manufacturers using Commport's EDI platform embed the TLC into every EDI 856 ASN at point of shipment. Commport's GDSN Datapool manages all GTIN-linked cheese attributes (variety, pasteurization status, net weight, allergens, country of origin). When FDA requests records linked to a specific TLC, Commport's platform delivers the complete dataset within the required 24-hour window.