No. Post offices and express courier facilities are not required to register as food facilities. The
activities of postal services and express courier services are focused on the transport of goods.
Their facilities generally serve only as a point of transfer of packages and other freight, including
packages containing food. Thus, it is appropriate to view both types of facilities as part of the
transportation process. The definition of “facility” in 21 CFR 1.227 provides that transport
vehicles are not facilities “if they hold food only in the usual course of business as carriers”.
Although FDA did not define “transport vehicle” for the purpose of food facility registration, the
Agency’s definition of “transporter” in 21 CFR 1.328, relating to the establishment and
maintenance of records, is relevant. “Transporter” is defined as “a person who has possession,
custody, or control of an article of food in the United States for the sole purpose of transporting
the food…” FDA believes that it is appropriate to apply this same rationale to exclude from
registration facilities that hold food only because they are part of the process of transporting it
from one location to another. This analysis is also consistent with the definition of “facility” in 21
CFR 1.227. Thus, because post offices and express courier facilities operating in a manner
comparable to post offices are part of the transportation network and have possession, custody, or
control of food for the sole purpose of transporting, they are not required to register as food
facilities.
