Food retailers, wholesalers, manufacturers and suppliers everywhere are working on the largest supply chain data collaboration project in history. The FDA’s final rule on food traceability (FSMA 204) requires additional traceability record keeping whenever foods such as tomatoes, all types of peppers, soft cheeses, nut butters, certain seafood, etc. change hands or change form.
The FDA’s rules are complex, as are its data requirements, but America’s leading grocery retailers and wholesalers are taking traceability a step further, requiring more data on more foods in less time than the FDA. Now, industry trends toward traceability are driven as much by competitors as by legal and regulatory threats from FDA legislation.
What are major retailers and wholesalers doing about traceability?
Over the past few months, major retailers including Kroger, Walmart and Target have communicated publicly about traceability, outlining specific requirements for their suppliers. To further strengthen their commitment to food safety and transparency within their supply chain, these retailers and others have tailored traceability programs to fit their business needs, including:
- adding All categories Or in some cases all food Applies to traceability programs that are not a subset of foods included on FDA’s Food Traceability List (FTL).
- More data elements are needed (FDA calls them “Key Data Elements” or “KDEs”).
- Setting a deadline is earlier This extends beyond the FDA’s deadline of January 20, 2026.
Not only have these major retailers already launched traceability programs, they have also built programs that are more robust than the FDA. Suppliers have already started signing up and participating, and consumers are taking notice.
As a result, pressure within the industry became more intense. The problem for other retailers and wholesalers is now that they are essentially competitive. Would consumers want to buy a brand that can’t or won’t provide traceability? Probably not. As an operator, do you want to explain to your CEO why your company can’t or won’t do traceability while your competitors are doing it smoothly? Probably not.
Does your supplier have the technical capability to perform traceability?
Up to 70% of vendors do not have an information technology (IT) department or general technical support staff to support the data exchange required for tracking. In addition to technical challenges, vendors face a variety of data requirements for each customer they serve. For many suppliers, traceability can be an impossible task without the help of the right technology partner.
What data should I share?
portion but that’s not the case every Traceability data can be printed on the label. The only reason is portion but that’s not the case every Traceability data is available once the labels are printed. Instead, this traceability data should be: transmitted electronically For all deliveries combined We use the data from the labels to form a complete traceability record.
Where does the rest of the traceability data come from?
Most suppliers already have this information in documents such as shipping notices (ASN), bills of lading (BOL), or within existing systems such as warehouse management systems (WMS) or accounting systems. All you have to do is extract and share that data every time a shipment is sent.
Watch this video to learn more about why. The label itself is not traceable.
Is there still time to start a traceability program?
The FDA’s enforcement deadline is just over a year away. The first strategic step retailers and wholesalers should take is to reach out to suppliers and build connections. That means you need to:
- Determine and document traceability requirements to ensure that, at a minimum, your program meets the requirements of FSMA 204.
- Review each supplier’s product list to see which foods and SKUs appear in FTL.
- Please contact each supplier to determine the following:
- Describe the FSMA 204 Food Traceability Final Rule and any additional traceability requirements established by your company. Answer questions or solve problems related to your unique operations.
- Let us help you determine which traceability data elements (KDEs) you need and find them within your existing labels, systems and documents.
- Establish requirements for data formatting and communication and test with each vendor.
- Create an error identification and correction process for missing or incomplete data and ensure each vendor understands how to make corrections.
Traceability has its advantages. Having data and increasing visibility into your supply chain creates opportunities to increase efficiencies in backdoor receiving, invoice reconciliation and accounting, and even inventory and waste management. There is tremendous pressure to meet or exceed the FDA’s FSMA 204 food traceability law requirements.
ReposiTrak Tracking Network® It was designed with guidance from grocery retailers and industry organizations to be a fast, easy-to-use and incredibly affordable food tracking solution. This has been our guiding principle and we stick to it.
To learn more about how ReposiTrak can help, contact ReposiTrak today.
