On September 30, 2025, the U.S. Food and Drug Administration (FDA) released a constituent update announcing new frequently asked questions (FAQs) related to the agricultural water requirements in the Food Safety Modernization Act (FSMA) Produce Safety Rule, as well as updated information on how it will implement the pre-harvest agricultural water requirements.
The FAQs were developed to provide information about the agricultural water requirements based on topics covered in the final rules, including the following:
- Inspection and maintenance of agricultural water systems,
- Pre-harvest agricultural water assessments (including testing as part of an assessment and assessment outcomes),
- Harvest and post-harvest agricultural water requirements,
- Corrective and mitigation measures, and
- Agricultural water treatment.
The FDA also released updated information about how it plans to implement the pre-harvest agricultural water provisions of the Produce Safety Rule. The updated information focuses on the key elements of the agency’s approach to FSMA implementation, including education (for both industry and regulators), industry training, technical assistance, inspections, and compliance with a commitment to taking an “educate before and while we regulate” approach.
Pre-Harvest Agricultural Water Final Rule Compliance Dates
The compliance date for the pre-harvest agricultural water requirements of the FSMA Produce Safety Rule began for Large Farms[1] starting on April 7, 2025. Compliance dates for Small Farms[2] and Very Small Farms[3] will follow in 2026 and 2027, respectively.
- Large Farms: April 7, 2025
- Small Farms: April 6, 2026
- Very Small Farms: April 5, 2027
[1] Under the FSMA Produce Safety Rule, farms sizes are classified by the average annual gross produce sales adjusted for inflation over a 3-year period. Click here to learn more about the FSMA Inflation Adjusted Cut Offs. “Large” farms have average annual produce sales above $500,000 adjusted for inflation.
[2] “Small” farms have average annual produce sales above $250,000 and up to $500,000 adjusted for inflation.
[3] “Very Small” farms have average annual produce sales above $25,000 and up to $250,000 adjusted for inflation.
Additional Resources
Resources including educational materials, Produce Safety Alliance (PSA) Grower Trainings, On-Farm Readiness Reviews and the California Department of Agriculture (CDFA) Technical Assistance Program are available to assist you with preparing for the pre-harvest agricultural water requirements.
FDA Links
- FDA Constituent Update
- FDA Frequently Asked Questions: Agricultural Water Requirements under the FSMA Produce Safety Rule
- FDA FSMA Final Rule on Pre-Harvest Agricultural Water
- FDA Requirements for Harvest and Post-Harvest Agricultural Water in Subpart E for Covered Produce Other than Sprouts
If you have questions about the Produce Safety Rule, please contact producesafety@cdfa.ca.gov. To stay up to date with news related to CDFA’s Produce Safety Program, sign up for the Produce Safety Program Mailing List by checking the Inspection Services Division (ISD) / Inspection and Compliance Branch / Produce Safety Program box. To learn more about CDFA’s Produce Safety Program, please visit https://www.cdfa.ca.gov/producesafety/.