The relationship between retailers and suppliers is changing due to FSMA section 204.
I attended the GS1 Connect Amplify conference in Nashville earlier this month to attend The FSMA 204 traceability sessions. The “Retailers’ Shared Vision for FSMA Rule 204 Preparedness” session was hosted by Amy Behm, GS1 Director of Customer Success for Industry Initiatives, and had panelists from Kroger, Wegmans, and Target representing a larger Retailers FSMA 204 work group. Their message was loud and clear– they are moving forward with FSMA 204 compliance preparations now and expect their suppliers to do the same. While suppliers are focused on the products they sell and getting source and growing locations that span their operations, retailers need to ensure all their suppliers of FTL items are ready within the next 24 months. The FDA’s proposed delay gives retailers extra time, but to accomplish compliance they are moving full steam ahead now. Keep in mind that FSMA 204 requirements extend to any product that has ingredients that are on the FDA’s Food Traceability List (FTL) that have not undergone a kill step to eliminate potential microbial contaminants.
During one of the sessions, I asked, “If FSMA compliance efforts were still underway, why have we not seen new requirements”. The answer I got was that for now the key requirements are the PTI Harmonized Case Label and an SSCC (Serialized Shipping Container Code) which they have already published. Currently they are working on updating their Advanced Shipping Notice (ASN) requirements to include the Key Data Elements (KDEs) of the Shipping Critical Tracking Events (CTEs) included with the ASN. All of the retail panelists stated their companies preferred method of getting the Shipping CTE in an ASN and were investigating alternate methods for smaller suppliers. Walmart has had a supplier portal allowing keyed data entry for those not doing ASN’s for a number of years. Perhaps we will see something similar from other retailers, time will tell.
The session also confirmed that while retailers will be focused on first getting FSMA 204 data on product on the FDA’s FTL, they will be expanding those requirements to all produce items. I walked away with a clear understanding that having FSMA 204 traceability compliance now is a competitive advantage leading up to the FDA’s proposed July 20, 2028, mandatory compliance date.
Final thought: Now that we know FSMA 204 traceability requirements are known, when there is a significant foodborne illness outbreak and you are not compliant, or at least demonstrably working on compliance, are you exposing your company to additional risk in civil suits for negligence?
I have a hunch prominent food safety attorney Bill Mahler would say yes.
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