by Ron Margulis / ReposiTrak
Many of the country’s largest food retailers are actively embracing full traceability under FSMA 204 as both a regulatory mandate and a critical business strategy.
Driven by major chains like Walmart, Kroger and Albertsons, the push for comprehensive recordkeeping is transforming the grocery industry, setting new performance standards for the entire supply chain. In fact, more than 50 leading retailers now require digital traceability from all suppliers as a prerequisite to market access.
FSMA 204: New era
FSMA 204, a key provision of the Food Safety Modernization Act, was established to bolster public health by making food traceability mandatory for high-risk foods.
The FDA Food Traceability List (FTL) specifies which products are covered, focusing on items most vulnerable to contamination, such as leafy greens, fresh-cut fruits, cheeses and seafood.
The rule’s purpose is to enable rapid response to outbreaks by requiring everyone in the supply chain – growers, processors, distributors and retailers – to maintain stringent tracking records for these foods, thus minimizing the impact of recalls.
FSMA 204 introduces two foundational concepts – critical tracking events (CTEs) and key data elements (KDEs). CTEs are checkpoints in the supply chain – shipping, receiving and transformation – that require documentation.
At each CTE, businesses must record KDEs such as traceability lot codes, supplier and receiver details, production and expiration dates, case and pallet identification codes and quantities shipped. These comprehensive data sets must be retained and made available to the FDA within 24 hours in the event of an investigation or recall.
The FDA, recognizing supply chain challenges, recently extended the compliance deadline from January 2026 to July 2028, giving industry stakeholders additional time to meet requirements and implement robust systems.
Routine inspections are expected to begin soon after, with new support resources and FAQs published to help processors, retailers and suppliers adapt.
Large grocery chains are taking FSMA 204 a step further, demanding full traceability across all food products, not just those on the FTL:
- Walmart requires suppliers to implement FSMA 204 protocols – including transmitting detailed KDE data through Advance Shipping Notices (ASN) and EPCIS standards – well ahead of the FDA deadline, applying the rules industry-wide.
- Kroger mandates traceability for all foods entering its facilities, regardless of FDA listing, with an even earlier compliance deadline of June 30, 2025. Kroger’s process relies on EDI 856 ASN documents for every shipment, barcode alignment and strict verification at receiving docks.
- Albertsons enforces a no-exceptions policy for all suppliers, requiring electronic ASN submissions, GS1 barcodes on pallets and cases and presence of KDEs in every reference document (bill of lading, packing list, invoice).
These efforts compel suppliers to raise their standards, fueling widespread supply chain improvements and increased accountability.
[RELATED: FDA Extends Date For FSMA 204 Compliance]
Business drivers
Traceability enhances food safety by allowing companies to quickly pinpoint the origin and destination of affected products, reducing the time and scope of recalls.
Recent foodborne illness events illustrate how digitized traceability data speeds the removal of contaminated items, protecting consumers and limiting business disruption.
Traceability technology can reduce the scope of a recall by 50-95 percent, enabling retailers to efficiently remove affected products, according to the International Trade Centre.
Transparency is now central to brand reputation. Shoppers increasingly expect retailers to provide information about food origins, handling and safety, reinforcing companies’ commitments to quality and integrity.
More than 75 percent of grocery shoppers now consider transparency about ingredients and food sourcing important – an increase from 69 percent in 2018 and 72 percent in 2021, according to FMI – The Food Industry Association. And 68 percent of global consumers prefer food products with visible traceability labels, per MarketGrowthReports research.
Transparency is now a driver for brand loyalty, trust and purchase decisions. FMI’s 2023 report found that eight in 10 shoppers would switch brands for greater transparency.
Enhanced traceability leads to improved inventory management, reduced shrink and the ability to rapidly adjust to supply chain disruptions. Digitized tracking supports better analytics and optimization, enabling leaner operations and less food waste.
More than 64,000 food companies migrated to cloud-based traceability platforms in 2023, reducing record-keeping costs by 22 percent according to MarketGrowthReports.
Companies that proactively comply with FSMA 204 position themselves as preferred partners for major retailers. Early adopters may access new markets, secure large contracts and build durable business relationships with industry leaders.
“It’s clear that the industry is moving toward traceability for all grocery products,” said Russ Greenlaw, COO of Associated Grocers of New England. “Many major retailers have already established this as a requirement, and we want to be prepared for it.
“Our shoppers also want to be assured the food they’re buying is safe, and we can see the opportunity for performance benefits to our business that can come from a better-connected supply chain with even more visibility.”
Challenges, solutions
Suppliers often encounter technology gaps, unforeseen costs, training challenges and integration issues when aligning with FSMA 204 and retailer-specific requirements. Legacy systems may not capture or transmit KDEs, leading to vulnerabilities.
Retailers offer guidance, technical assistance and documentation. Third-party traceability platforms and industry associations play supportive roles, helping with implementation, onboarding and ongoing compliance monitoring. Collaborative supplier forums and technology partnerships are emerging as best practice hubs.
Suppliers that have successfully adopted robust traceability systems report reduced recall impacts, strengthened retailer relationships and higher operational efficiency. Lessons include the value of early engagement, multi-stakeholder collaboration and investment in scalable data technology.
“Several of our customers are already asking for food traceability data and each has a unique set of requirements. As more retailers and wholesalers work to establish their food traceability requirements, we know that what’s being asked of us as a supplier is going to become more complex,” said James Barth, food safety specialist with Capital City Fruit Co.
“By preparing now, with the help of a third party, we’re able to scale to support our customers. Traceability has become a point of difference for us, and it shows that we’re committed to a safer, more connected supply chain.”
Future
FSMA requirements are likely to expand as the FDA refines the FTL and adapts to new food safety risks. Global retailers increasingly require harmonized traceability standards, prompting international cooperation and regulatory alignment.
The adoption of IoT devices, artificial intelligence and similar technologies is accelerating, enabling real-time visibility and predictive risk management. Digital labeling tools and consumer-facing traceability platforms offer direct access to product origin and safety data at the point of sale.
“As companies strengthen food safety standards, food traceability requirements are more than a compliance mandate – they are a catalyst for digital transparency and technology innovation, driving a future where trust, accountability and smarter systems reshape the way we grow, move and consume food,” said Randy Fields, CEO of Salt Lake City, Utah-based ReposiTrak, a food traceability and regulatory compliance network.
Retailers will continue to elevate traceability standards, expanding programs to more product categories and integrating traceability data into sustainability and environmental, social and governance (ESG) reporting. Demonstrated traceability is likely to become a core requirement for supplier contracts and market participation.
Business imperative
Full traceability is no longer just legal compliance – it’s an operational and reputational necessity for the modern grocery industry. The combination of FDA regulations and ambitious retailer programs is reshaping the supply chain, demanding better data, faster responsiveness and new technology adoption.
Investments by retailers now will help secure their businesses, build consumer trust and unlock competitive opportunities in a rapidly evolving marketplace.