Your Product Is Detained at the Port. Here's What the LAAF Rule Actually Requires.
Your shipment is detained. Now what?
That's when the LAAF rule stops being a regulatory abstraction. If you're dealing with an FDA import alert or a shipment held at the port, which labs are LAAF-accredited, and what they're actually accredited to test, becomes an urgent, practical question.
Each month, FSMA Friday brings together food safety professionals and regulatory experts to cut through what's actually changing. Last month's session featured Dr Dan Rice, DrPH, who spent years running the FDA's Office of Regulatory Testing and Surveillance before joining The Acheson Group. He walked through the Lab Accreditation for the Analysis of Foods (LAAF) rule: what it covers, when it applies, and what you need to know if you're a food or beverage manufacturer, importer, or both.
🎥 Watch the full session on-demand → FSMA's Lab Accreditation Rule: What Food & Beverage Manufacturers & Importers Need to Know
A Regulatory Change You May Have Missed
Before getting into LAAF, Dr Rice flagged something that quietly took effect on February 19, 2026: FDA revoked 21 CFR § 2.19. That regulation had required labs to fall back on the 1980 edition of AOAC methods whenever no specific method was named. In other words, a 45-year-old default was still on the books. It's off now; and if your labs were already using more current, validated methods, this change simply removes an old ambiguity and puts them on firmer footing.
What LAAF Is and Whether It Applies to You
LAAF came out of the Food Safety Modernization Act and was finalized in December 2021. The structure: FDA recognizes accrediting bodies, those bodies assess and certify labs, and those labs run specific food tests and submit results to FDA for review.
Here's what LAAF does not cover: routine surveillance testing, outbreak investigations, or most domestic food testing. It's scoped to situations involving heightened food safety risk, specifically around imported products, and it lives in 21 CFR sections 1.1101–1.1200.
You'd need a LAAF lab in three situations:
- Import alerts: If your product is on an FDA import alert (DWPE) for a covered analyte, you'll need LAAF lab testing to get it removed
- Detained food: If your product is held at the border under section 801(a) of the FD&C Act, LAAF testing can support getting it into commerce
- Directed orders: If FDA issues a specific laboratory order targeting a known food safety issue
For most importers and manufacturers, the first two are what actually come up.
Which Analytes Are Covered and What's Being Added
LAAF went live on May 31, 2024, starting with mycotoxins only. Since then, the list has grown. FDA reached sufficient lab capacity for two additional analytes in June 2025, which started the six-month compliance clock; so if your product involves either of these, testing requirements have been in effect since December 2025:
- Listeria monocytogenes
- Melamine and cyanuric acid: chemicals that have been introduced into imported whey proteins to make protein content look higher than it is
More analytes are coming. Pesticides are expected. So is Salmonella testing for shell eggs. The pattern stays the same: once FDA confirms enough lab capacity exists, you get six months to comply.
Your best tool for staying current is the FDA LAAF dashboard. Dr Rice walked through it during the session — it shows you which analytes are active, when compliance dates hit, which accrediting bodies are recognized, and which labs are approved and for what. Bookmark it if you work in import compliance.
How to Find the Right LAAF Lab
Every LAAF-participating lab must hold ISO/IEC 17025:2017 accreditation — the standard that covers both technical competency and quality management in testing labs. All FDA food testing labs are accredited to it. Most state regulatory labs are too.
The dashboard lets you search by lab name or analyte. Before you send anything, check that the test you need falls within that specific lab's current accreditation scope. LAAF accreditation doesn't cover every analyte — scope varies by lab. Don't assume; look it up.
One detail that catches people: whoever collects your samples doesn't need to be LAAF-accredited, but FDA still pays close attention to their qualifications. Sampler training records, written sampling plans, documentation of experience — FDA looks at all of it. Sloppy sample collection can sink a clean lab result.
Once your samples are in, FDA reviews the analytical package, confirms the method used is within that lab's scope, and concurs or asks for more. They may randomly audit packages too. Turnaround is built to be fast — Dr Rice confirmed current lab capacity is solid for all listed analytes, so delays aren't the concern they might have been early in the program.
🎥 Dr Rice walked through a live demo of the FDA LAAF dashboard during the session — watch the replay to see how to use it.
What to Ask When You're Evaluating Any Food Testing Lab
The second half of the session covered something that applies whether you're navigating LAAF or just choosing a testing partner: how to tell a well-run lab from one that will cause you problems. ISO/IEC 17025:2017 accreditation is the starting point, not the finish line. Here's what Dr Rice looks at beyond that.
Analyst competency programs.
Does the lab run proficiency testing? Are training records current for every staff member doing analytical work? Good labs treat this as an ongoing discipline, not something they addressed at hiring.
CAPA discipline.
Pull the corrective and preventive action data. How many are open? How long have they been open? If you're seeing CAPAs that have been sitting for 100, 200, or 300 days, that tells you something real about how the lab handles problems. A well-run lab closes them fast and uses each one to actually improve how it operates.
Documentation.
Instrument maintenance logs, calibration records, temperature monitoring, all of it should be current, complete, and accessible. Method SOPs should be locked so analysts can't edit them on the fly.
Analytical results documentation.
How results get recorded, reviewed, and reported matters. This is exactly what FDA auditors pull when they show up.
Chain of custody.
From the moment a sample is collected to the moment it's destroyed, you want a clear record of who touched it, how it was stored, and what happened at every step. If that chain has gaps, your results can be challenged.
Environmental monitoring.
Labs that test for pathogens should be running their own environmental monitoring programs testing the lab environment itself for the organisms they're testing your product for. If they're using PCR-based methods, they should also have controls in place to catch amplicon contamination.
Separation of quality and testing staff.
The people running the quality program shouldn't be the same people running the tests. That separation is a structural check, not a formality.
Auditing history.
Ask to see internal and external audit reports. Look at what findings came up and how the lab responded. Third-party accreditation assessments happen every two years; the reports are available and worth reading.
Culture.
Dr Rice was plain about this one: it's harder to measure than any of the above, and it matters more. You're looking for a lab where the quality system is how work actually gets done, not a set of binders that comes out during audits. As Dr Rice put it, it's about the process, not the person. When that's genuinely true, you see it in the CAPA data, in how staff talk about their work, in how the lab responds when something goes wrong.
Don't Wait Until You Have a Problem
If LAAF isn't affecting your day-to-day right now, that's probably going to change. The analyte list will grow. Domestic products will likely come into scope. Knowing how the accreditation system works, having the dashboard bookmarked, understanding which labs are qualified for what, that's groundwork you want laid before your product is sitting at a port.
Dr Rice’s advice for manufacturers running internal labs that aren't yet ISO/IEC 17025:2017 accredited: pursue it. It's not a light lift, but labs that go through the process come out running better: tighter operations, faster problem resolution, lower long-term costs. The discipline it instills pays for itself.
And when you're vetting third-party labs, use the criteria above. The right question isn't whether a lab can do the test. It's whether their results will hold up when it counts.
🎥 Ready to dig in? Watch the full FSMA Friday session on-demand including Dr Rice's live FDA dashboard demo and the full Q&A, where he covers Listeria environmental monitoring response, dietary supplement scope, and the mistakes importers most often make when they're trying to navigate LAAF.
FSMA Friday is a monthly series co-produced by The Acheson Group and SafetyChain. Past recordings and regulatory resources are in SafetyChain's resource library.
Next session — March 27, 9:00 AM PT / 12:00 PM ET: Don Kautter of The Acheson Group on working with FDA; practical insights from a former official.
Following session — April 24, 9:00 AM PT / 12:00 PM ET: Panel discussion on FDA, FSMA, and AI: navigating regulation, data, and compliance intelligence.
