
The food industry is facing significant change in an era where consumer demand for premium, “better-for-you” products is surging and avian flu is driving up egg prices, posing a potential risk to food companies. Major food manufacturers are poised to accelerate mergers and acquisitions in 2024 as they dominate the market with new product launches and ingredient innovations. While all this is happening The U.S. Food and Drug Administration (FDA) Food Safety Modernization Act (FSMA) Regulation 204 There is increasing pressure on food supply chains to meet traceability requirements.
FSMA Rule 204 requires unprecedented collaboration between trading partners to share traceability data that tests the complex web of supply chains comprised of manufacturers, suppliers, distributors, and retailers. With multiple handoffs and frequent changes in the supply chain, siled coordination can cause unintended disruptions if not aligned with the rest of the network.
Collaborative Communications: The Key to FSMA 204 Compliance
“It is important for food companies to begin communicating with their trading partners now to meet FSMA Rule 204 requirements by the January 20, 2026 deadline,” said Amy Behm, director of community engagement at GS1 US, a nonprofit global standards organization. . .
“In most cases, you are already collaborating regularly with people one level up or one level down in the supply chain, but don’t assume everything will come together later,” Behm said. “Ask now. ‘What are you preparing? Can you share anything from your tracking plan?’ Then you are Sorted.”
This kind of collaboration is at the heart of FSMA Rule 204, which is intended to allow the FDA to conduct better, faster investigations of foodborne illnesses or respond more quickly to recalls. Traceability between trading partners depends on coordinated documentation of key data elements such as traceability lot code (TLC) and traceability lot code source.
“This is a big change that catches everyone off guard,” Behm said. Every organization will always have a way of identifying the source and destination of items within its territory, but the challenge is to identify the items in the same way to its next trading partner. TLC and TLC Source provide identifiers that follow products throughout the entire supply chain.
The outbreak of avian flu and its impact on egg prices highlights the importance of traceability. “The need for traceability was demonstrated in real time,” Behm said. “Here is an example of a current event that shows why it is important to secure and understand all identifiers. accurately Where does the product come from?”
Records during the current recall period range from spreadsheets to handwritten records. “It could take the FDA months to connect the dots of all these records,” Behm said. “Using standardized identifiers helps the FDA potentially shorten these investigations to just a few days.”
Standardized identifiers, such as those provided by GS1, enable the seamless exchange of key data elements throughout the supply chain, enabling faster and more accurate tracking. For example, although there is no required format for traceable lot codes and traceable lot code sources (they must be consistent throughout), industry-recognized best practices state that: International Trade Item Number® (GTIN®) Can be used with batch/lot information and associated date Application Identifier (AI) for traceability lot code. Global Location Number (GLN) Traceability can be used to identify the required location for lot code sources.
Companies are now faced with the challenge of further segmenting their location identifiers beyond the single global location number (GLN) of headquarters. For example, a manufacturer with multiple production facilities or a farmer with multiple fields could assign a unique GLN to each location. This allows accurate identification of disease outbreaks and limits the impact to specific areas rather than shutting down entire operations. Accordingly, the following platforms GS1 US Data Hub | location Behm said he is playing an important role in strengthening traceability efforts.
The platform allows businesses to assign detailed location information and grant access to trading partners to facilitate data viewing and verification. This level of specificity and transparency is critical for effective traceability in the food supply chain.
Addressing FSMA 204 and industry requirements
Facing further industry change, food companies are trying to balance the pressure to launch new products, demand for better premium products, price volatility and ingredient innovation with the need to implement robust traceability systems and FSMA Rule 204. Another concern is climate. Mergers and acquisitions in the food industry and potential disruption of traceability efforts.
If the GS1 standard goes into effect, these kinds of corporate changes will have minimal impact on traceability plans, Behm said. This standard allows companies to use essentially the same language in terms of product and location identification, allowing for smoother transitions during mergers and acquisitions, even when companies undergo significant structural changes.
“The key is not to overcomplicate the process,” Behm said. “Production companies should be able to check in advance whether their products are on the FDA’s food tracking list. Many trading partners will begin looking to upgrade their master data systems to include this new information, so simply knowing whether your products are subject to FSMA Rule 204 will be helpful. This requires the manufacturer to maintain additional records of these items. .”
the way forward
As the food industry grapples with demanding requirements, GS1 US Data Hub | Location provides a clear path for effective communication and collaboration between trading partners. “The most common mistake today is assuming that FSMA Rule 204 compliance is too much or too difficult and not starting now,” Behm said.
About GS1 US:
GS1 USA® By strengthening their supply chains, companies can deliver safe, consistent, secure, and trustworthy experiences. Best known as the source for UPC barcodes, GS1 is a non-profit global data standards organization that creates a common language for companies to identify, capture and share trusted data that connects their physical and digital supply chains. Millions of businesses around the world are powering commerce with GS1 standards. Learn more www.gs1us.org.









