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In just over a year, grocers and suppliers will have to comply with the Food and Drug Administration’s new food tracking requirements, but a new report says some key questions remain.
The grocery industry trade association said the rule, which has a compliance date of Jan. 20, 2026, represents the biggest food safety change retailers have seen in more than a decade. A New Report from the Reagan-Udall Foundation for the FDA When executives try to follow the company’s rules, they look at which parts of the rules are confusing.
This report is based on three industry roundtables the foundation hosted this spring, attended by about 20 people, including executives from General Mills, Food Industry Institute (FMI), Subway, the International Fresh Produce Association, and United Natural Foods, Inc.
According to the report, the top compliance challenges participants said they faced were: The Reagan-Udall Foundation for FDA plans to explore these key issues. Virtual Public Meeting This rule takes effect on October 7.
Labeling level for traceability lot code (TLC)
Under the rules, companies transporting food must provide recipients with information on the TLC for each lot of food and where the food is coded. According to the report, participants said they wanted clarification on the extent of labeling and tracking activities required, and better definitions of the information required for TLC.
The report noted that “for example, some participants believed that case-level labeling and tracking were essential to generating the information needed, but case-level labeling and tracking were not explicitly required.”
Warehouse Management System
The report noted that warehouse management systems vary significantly across the industry and “most are likely unable to capture all (essential data points) without significant upgrades or complete system replacement.”
Given the labor intensity of labeling and scanning every box of food and the fact that pallets may contain mixed products, participants wondered whether a “most likely” lot code or probability calculation would be acceptable.
Reporting Indicators
Participants reported confusion about when they were required to submit completed spreadsheet templates to provide the information requested by FDA.
“Participants suggested making the training portion of the spreadsheet template more accessible and providing a sample ‘finished template’ to demonstrate expectations for each segment of the supply chain,” the report said.
The report continues: “Participants were also asked to test the spreadsheet with real or simulated data from across the supply chain, from farms to restaurants and retailers, to identify adjustments that could improve adoption and usability.”
FDA Investigation Process
When a foodborne illness outbreak occurs, participants said they have questions about what happens when multiple lot codes are submitted to FDA for review. They also raised concerns about what to do about “damaged, illegible, improperly encoded, or missing labels” that could lead to unreliable reporting.
Next Steps
Since the rule was announced in November 2022, industry pilot programs have aimed to test the current system and identify changes, but “most” have focused on just one food product or category, according to the report.
Participants called for more pilots, along with templates for running them, a space to share learnings, and tailored testing for small, medium, and large businesses.
Participants also said they would like to explore public-private partnerships where cross-sector companies work with state regulators and public health agencies. Such partnerships could help support implementation, create consistency in data structures, requirements, timing, and standards, provide space for pilot results, and gather information to share with FDA.
The FDA has indicated it is willing to engage in public-private partnerships, the report said.
It’s unclear how feasible this proposal would be, but some participants expressed support for adjusting compliance dates for the rules by sector or company size, the report said.
“Since each segment of the supply chain (buyer) relies on information provided by previous segment participants (supplier), sector-specific implementation can create a roadmap to compliance starting at the beginning of the supply chain and working through to retail,” the report said.
