Traceability of high-risk food is now the law under the Food Safety Modernization Act, and time is running short to get into compliance.
The deadline for compliance is January 2026 – by the calendar, that’s two years away, but when you subtract weekends, days off and the annual holiday rush periods when operators typically avoid launching tech or process projects, you’re looking at barely a year of business days to make things right. So, there’s no time to waste.
In a recent webinar hosted by the National Grocers Association, as part of NGA’s official partnership with ReposiTrak on traceability and compliance, ReposiTrak Chief Customer Officer Derek Hannum offered guidance on the decisions to make and the actions to take to bring your company into compliance before enforcement begins.
“The amount of time and effort required to develop and implement a traceability program is far greater than most people think,” Hannum stressed.
Here are some key takeaways from the discussion:
Your company is now part of the largest supply chain data collaboration in history. Up to 2 million stores, restaurants, distribution centers, production facilities and packing houses need to create and manage food traceability records, and most are not equipped to do it. This is not a food safety project – it’s a supply chain data management project.
Who is required to do traceability? Per the FDA, anyone that manufactures, processes, packs or holds food on the food traceability list (FTL) must maintain records including key data elements (KDEs) related to critical tracking events (CTEs) and provide information in an electronic sortable spreadsheet to the FDA within 24 hours. Records must be retained for two years.
What categories of products need to be tracked? Soft cheeses, shell eggs, nut butters, cucumbers, fresh herbs, leafy greens, melons, peppers, sprouts, tomatoes, tropical tree fruits, fresh-cut fruits and vegetables, finfish, crustaceans, mollusks and ready-to-eat deli salads. For supermarkets, this impacts the produce, dairy, seafood, deli/prepared foods, center store and frozen departments.
When does FSMA 204 enforcement start? The final rule became effective last Jan. 20. Compliance is required by Jan. 20, 2026.
CTEs that impact retailers, wholesalers and distributors are shipping, receiving and, in some cases, transformation.
What is transformation? It’s taking one or more items from the FTL and transforming them to create a new item that is on the FTL. For example, tomatoes and peppers used in a deli salad; the ingredients and the final products are all on the FTL. Repacking is considered transformation but only applies if the transformation happens in a facility that does not sell the product directly to consumers, such as a processing facility or a central kitchen.
The big challenges. For suppliers, your customers need to receive traceability lot code and lot code source reference data from you; if you don’t already track these, you need to start. At DCs, lot codes currently are not tracked; DCs can’t create KDE records if they don’t have a way to collect and track lot codes. Retailers must have a KDE receiving record for products received at the store, warehouse and DSD items.
Labels are required but aren’t the complete solution. All cases/shipping units need to have identifying lot code information. Adopt the GS1 standard. Labels only carry KDEs, not the shipment data, so labels alone can’t be used to generate the required KDE record.
What steps must I take now to get ready? Retailers and wholesalers should identify the products and suppliers requiring traceability under FSMA 204, identify the DC/warehouse systems and processes that need to change, understand the requirements of retail stores and what systems and processes need to change, and identify and establish the human and technology infrastructure required to support traceability.
Time is running out to get in compliance. Every retailer, wholesaler and producer of covered items needs to collect and retain traceability data for two years. You can’t go alone – the process involves the collaboration of trading partners. The work and time involved is even greater than you realize.
Visit the NGA/ReposiTrak traceability resource center at https://www.nationalgrocers.org/m/repositrak/resources/.
For more exclusive insights, view a recording of the complete webinar here: https://attendee.gotowebinar.com/recording/8908848375320071850.
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