Food traceability is now the law under the FDA’s FSMA 204 Food Traceability Final Rule. Grocery retailers, wholesalers, food manufacturers and suppliers are now responsible for keeping more traceability records than ever before. Although the FSMA 204 implementation deadline of January 20, 2026 is rapidly approaching, some persistent misunderstandings risk slowing the adoption of traceability practices across the supply chain.
The most common misconceptions among grocery retailers relate to the viability of labels as a tracking solution, confusion surrounding the legal and regulatory risks of non-compliance, and general uncertainty about how to initiate a FSMA 204 compliant tracking program.
In this article, I will explain three truths that may be controversial but can undoubtedly shed light on the big picture in this short time frame the industry is working with.
Truth #1: No, labels are not trackable.
Why not? Even though that is true portion Some of the information printed on the label must be part of the traceability records required by the FDA. every That information could have been known at the time, let alone printed.
Think of it this way. Once a label has been printed and attached to a package or box, the supplier usually knows it and has it on hand.:
- Traceability Lot Code (TLC) for Food
- Product description for food
- Location description for TLC source or TLC source reference
However, at the time the label is printed, there is no way to know or have information about transactions that have not yet occurred involving that product. For example, there is no way to know when a label has been printed.:
- A description of where the food was received
- A description of the location of the immediate source of the food (excluding the food transporter)
- Reference document type and reference document number
- Food quantities and units of measurement
- Date the food was received
So where do the other KDEs come from? KDEs that cannot be printed on labels are typically found in existing systems or documents such as shipping notices (ASNs), bills of lading (BOL), warehouse management systems (WMS), or accounting systems. I need to send this KDE electronically For all deliveries… And then combined Use the KDE on the label to form a complete KDE record as required by the FDA.
To find out what I mean, Watch this short 90-second video about why labels don’t do their own traceability..
Truth #2: There are real legal risks if you do not or will not comply with FSMA 204.
The FDA is likely to impose its first and heaviest sanctions on retailers where end consumers purchase food. This is where traceability peaks and data is aggregated. This is also where the investigation begins. If a company is unable to demonstrate compliance with FSMA 204 or determines that its traceability efforts are insufficient, the FDA has powerful remedies that it can and will deploy.
Traceability has changed the food supply chain industry forever. This has also brought new pressures in the form of regulatory and illegal activity risks never seen before. The legal threats posed by traceability are discussed in detail below. Recently Hosted Webinars ReposiTrak and Best Food Safety Attorney Shawn Stevens.
Here are some key takeaways from the webinar on the legal threats of FSMA 204:
- Each party in the supply chain has a legal obligation (and a duty to consumers) under the law to ensure that they are doing their part to collect and share the information needed for traceability.
- If a retailer chooses to do business with a supplier that refuses to track, they do so at their own risk. If your supplier refuses to track, you may want to consider finding another supplier who will do this.
- The FDA will initiate any investigation with the retailer. Therefore, retailers must have a strong tracking plan and record keeping.
Truth #3: There is no time to waste
With the FDA’s implementation deadline for FSMA 204 still more than a year away, some companies think they have time to start their traceability programs. In fact, tracking takes time and requires establishing technical connections with all affected suppliers, regardless of their level of sophistication.
If you are a retailer or wholesaler considering whether to start a tracking program now, consider the following:
In summary, the truth about traceability is that labels alone are not enough, there are real legal threats to companies that do not comply, and there is no time to waste. Adopt a truly technology-based food traceability program As stated by FDA Requires time, people and financial resources. Getting started now will help you spread your valuable resources more evenly over time, minimizing disruption and creating a smoother transition to full compliance.
Also, keep in mind that traceability data starts with the supplier. This is where the most important KDE “Traceability Lot Code” or “TLC” comes from. To perform traceability, a retailer or wholesaler must establish physical and technical connections with all affected suppliers, regardless of their level of technical knowledge. Through our work onboarding suppliers for compliance and traceability over the past 20 years, we have found that over 70% of suppliers do not have dedicated IT resources.
Exchanging this much data will result in errors. All FSMA 204 food traceability programs must consider the methods, time, and resources needed to identify errors and correct and document solutions.
The essence of FDA’s FSMA 204 food traceability final rule is to take proactive steps to improve food safety throughout the food supply chain. According to the FDA, these traceability requirements “will allow for faster identification and rapid removal of potentially contaminated food from the market, reducing foodborne illnesses and/or deaths.”
FSMA 204 is complex and its impact will be felt broadly throughout the retail grocery industry. An important first step to meeting your needs is making connections with each vendor to understand what KDE they have and how they can share KDE with you. You can do this yourself, or use an established solution like the ReposiTrak Traceability Network, the world’s only operational traceability network that already has hundreds of supplier connections with thousands more in its queue.
To learn more about traceability and the ReposiTrak traceability network Contact ReposiTrak today. We are happy to help.
