Qualified Facility Exemption for Cricket Flour: Are You Eligible?

A cricket flour facility with less than $1M in average annual sales that sells more than half its product directly to consumers or local retailers may qualify for the Qualified Facility Exemption. If you qualify, you're exempt from FSMA's Preventive Controls requirements - no written food safety plan, no PCQI, no required monitoring records under the preventive controls framework. You still need to follow basic GMP requirements, but the full preventive controls compliance burden doesn't apply to you.

Many small cricket flour producers qualify for the QFE but don't know it. They're building elaborate compliance programs for regulations that don't apply to them, spending time and money on requirements they could avoid. This guide tells you whether you qualify and what the exemption requires.

TL;DR

• A cricket flour facility with less than $1M in average annual sales that sells more than half its product directly to consumers or local retailers may qualify for the Qualified Facility Exemption.
• This is calculated based on the 3-year average preceding the year you claim the exemption.
• If your business grows above the $1M threshold, you must comply with the full Preventive Controls requirements.
• You still need to follow basic GMP requirements, but the full preventive controls compliance burden doesn't apply to you.
• Many small cricket flour producers qualify for the QFE but don't know it.
• They're building elaborate compliance programs for regulations that don't apply to them, spending time and money on requirements they could avoid.
• The exemption recognizes that small, local food producers with direct consumer relationships pose different risk profiles than large-scale commercial processors.

What the Qualified Facility Exemption Is

The Qualified Facility Exemption (QFE) is a provision in FSMA's Preventive Controls for Human Food rule (21 CFR Part 117) that exempts small food producers from the full Preventive Controls requirements. The exemption recognizes that small, local food producers with direct consumer relationships pose different risk profiles than large-scale commercial processors.

The QFE is not an exemption from all food safety requirements. You still need to:

• Register your facility with FDA
• Follow GMP requirements (21 CFR Part 117 Subpart B)
• Comply with labeling requirements
• Display the required disclosure statement on your product labels

You're exempt from Subpart C (Hazard Analysis) and Subpart D (Supply Chain Program) - the major preventive controls compliance requirements.

Eligibility Criteria

To qualify for the QFE, you must meet two conditions simultaneously:

Condition 1: Sales threshold

Your facility must have average annual food sales of less than $1,000,000 (indexed to inflation from 2011 baseline, currently approximately $1.3M as of 2026). This is calculated based on the 3-year average preceding the year you claim the exemption. If you're a new facility, you use your projected sales.

Condition 2: Direct sales requirement

More than 50% of your food sales must be directly to:

• Qualified end-users (the consumer who purchases directly from you, or a restaurant or retailer located in the same state or within 275 miles of your facility), or
• A retail food establishment that sells directly to end-users

This is the "local" requirement. If you're primarily selling at farmers markets, through your own e-commerce site, to local restaurants, or to local retailers - and these sales represent more than half of your total food sales - you likely meet this condition.

What doesn't count toward the direct sales requirement: Sales to wholesalers, distributors, or out-of-state buyers don't count toward your 50% threshold. If you're primarily selling to a national online retailer or shipping to buyers across the country, you may not meet the direct sales requirement even if your total sales are under the threshold.

The Disclosure Statement Requirement

If you use the QFE, your product labels must include a disclosure statement. The required disclosure:

> "This food was produced by a qualified facility that is exempt from subpart C (Hazard Analysis and Risk-Based Preventive Controls) and subpart D (Supply Chain Program) of part 117 of title 21, Code of Federal Regulations."

This statement must appear on your label along with the name and complete business address of the facility where the food was produced. It's telling consumers that your product was made under the modified compliance framework.

The disclosure statement is a label space consideration. For small packages, the statement can appear anywhere on the label as long as it's legible.

When the QFE Doesn't Apply

The QFE is not available if your facility produces food for which there is a separate regulation (infant formula, dietary supplements subject to DSHEA, etc.). For cricket flour as a food ingredient or consumer product, the QFE is available if you meet the sales and direct marketing thresholds.

If your business grows above the $1M threshold, you must comply with the full Preventive Controls requirements. Plan for this in advance - if you're approaching the threshold, start building your food safety plan before you cross it.

For the full FDA compliance framework that applies when you don't qualify for the QFE, see cricket flour FDA compliance. For the FSMA Preventive Controls requirements, see FSMA preventive controls for cricket flour.

Frequently Asked Questions

Am I exempt from FSMA Preventive Controls as a small cricket flour producer?

You may be exempt under the Qualified Facility Exemption if two conditions are both met: your average annual food sales are below approximately $1.3M (indexed from the 2011 $1M baseline), AND more than 50% of your sales are directly to consumers, local restaurants, or local retailers within 275 miles of your facility or in the same state. If you meet both conditions, you're exempt from FSMA Subpart C (Hazard Analysis and Preventive Controls) and Subpart D (Supply Chain Program). You're still subject to GMP requirements, FDA facility registration, and labeling requirements. Review your current sales mix to determine whether you meet the direct sales requirement - that's where most borderline cases fall.

What is the Qualified Facility Exemption for cricket flour producers?

The QFE is an exemption from FSMA's Preventive Controls requirements for small, local food producers with less than $1M in average annual sales (approximately $1.3M inflation-adjusted for 2026) who sell more than half their product directly to consumers or local restaurants and retailers. Qualifying cricket flour producers don't need a written food safety plan, a PCQI, or FSMA Preventive Controls monitoring and record-keeping systems. They do need to register with FDA, follow GMP requirements, meet labeling requirements, and include a specific disclosure statement on their product labels stating that the food was produced by a qualified facility exempt from the preventive controls requirements.

What does a cricket flour producer need to display on its label to use the QFE?

If you claim the QFE, your label must include a disclosure statement reading: "This food was produced by a qualified facility that is exempt from subpart C (Hazard Analysis and Risk-Based Preventive Controls) and subpart D (Supply Chain Program) of part 117 of title 21, Code of Federal Regulations." This statement must appear on the label along with your facility's name and complete address. It can appear anywhere on the label as long as it's legible. Include it in your label design before printing, and keep documentation of your QFE eligibility (sales records showing the sales threshold and direct sales percentage) in case FDA ever questions your claimed exemption status.

How does CricketOps help track the metrics described in this article?

CricketOps provides bin-level logging for the variables that drive production outcomes -- feed inputs, environmental conditions, mortality events, and harvest results. Rather than maintaining these records in separate spreadsheets, you can view performance trends across bins and over time to identify which operational variables correlate with better outcomes in your specific facility.

Where can I find industry benchmarks to compare my operation's performance?

The North American Coalition for Insect Agriculture (NACIA) publishes periodic industry reports with production benchmarks. University extension programs in agricultural states, including the University of Georgia and University of Florida IFAS, occasionally publish insect farming production data. Industry conferences hosted by the Entomological Society of America and the Insects to Feed the World symposium series are additional sources of peer benchmarking data.

What is the biggest operational mistake cricket farmers make in their first year?

Expanding bin count before achieving consistent FCR and mortality targets in existing bins is the most common and costly first-year mistake. At 5-10 bins, problems are manageable. At 30-50 bins, the same proportional problems represent much larger financial losses. Most experienced cricket farmers recommend holding expansion until you have three consecutive production cycles hitting your FCR and mortality targets.

Sources

• Food and Agriculture Organization of the United Nations (FAO) -- Edible Insects: Future Prospects for Food and Feed Security
• North American Coalition for Insect Agriculture (NACIA)
• Entomological Society of America
• University of Georgia Cooperative Extension
• Journal of Insects as Food and Feed (Wageningen Academic Publishers)

Get Started with CricketOps

The practices covered in this article are easier to apply consistently when they are supported by organized production data. CricketOps gives cricket farmers the tools to track what matters -- by bin, by batch, and over time. Start your next production cycle in CricketOps and see how organized data changes the way you manage your operation.