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Get Ahead of the FDA’s New Food Traceability Rules.

The clock is ticking, the countdown to US FDA mandated traceability requirements is on. Here’s what you need to know about achieving compliance.

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FSMA Food Traceability Final Rule is Here.

The FDA Food Traceability Final Rules on Record Keeping and Reporting Rules, the Food Safety Modernization Act (FSMA) Section 204 are released bringing new requirements for tracking and reporting items on the Food Traceability list. With many food retailers requiring early compliance, it’s time for grower/shippers and distributors to act now to meet the January 2026 date.

Watch Our Quick Videos on What’s Changing.

Watch our overview videos to learn more about what’s changing with food traceability and what products require you to record Critical Tracking Events.

How Will FSMA Section 204 Impact
Produce Growers?
What Food Products Are Subject to
the New Rules?

Q&A for Grower Shippers

What is the FSMA Food Traceability Final Rule?

The Food Traceability Final Rule implements Section 204(d) of the FDA Food Safety Modernization Act (FSMA), its purpose is to provide means to faster identification of potentially contaminated foods enabling rapid removal from the market, resulting in fewer foodborne illnesses and/or deaths.

What Are the FDA’s New Food Traceability Requirements?

The FDA’s FSMA Food Traceability Final Rule requires companies to maintain and provide records of Critical Tracking Events (CTE’s) in the food supply chain. In produce these include reference to harvest locations, receiving, cooling, initial packing, transformation, and shipping. Key Data Elements (KDE’s) of these events must be captured and maintained, and it must be provided to supply chain partners and the FDA as needed. Maintaining these CTE’s and KDE’s are new additional requirements beyond just applying and recording PTI Harmonized Traceability Case Labels.

Who is Subject to These New Rules?

The Food Traceability Final Rule applies to persons who manufacture, process, pack, or hold foods on the FDA’s Food Traceability List (FTL). It covers domestic as well as foreign firms producing food for U.S. consumption, along the entire food supply chain.

Leading retailers are expected to require the same level of traceability for all their fresh produce citing challenges and liabilities of managing different traceability processes within the produce department.

What Foods Are Covered by the FSMA Final Rule?

Most vegetables, nut butters, and fish products are covered. The complete list is available on the FDA’s Food Traceability List.

When Do the New Requirements Go into Effect?

The compliance date for the new FSMA record keeping requirements is Tuesday, January 20, 2026, but retailers are pushing produce and other food suppliers to be compliant much sooner. If you are subject to these new rules, you need to get to work right away to ensure you’re ready to meet retailer requirements and protect your business.

How Do I Ensure Compliance?

To ensure compliance, you must capture and maintain Key Data Elements (KDEs) that record Critical Tracking Events (CTEs) in the food supply chain, and you must create a written Traceability Plan and assign Traceability Lot Codes (TLCs) where required. The best way to do this is by using digital software, data capture and tracking technologies to help automate the process.

What are Critical Tracking Events (CTEs) and Key Data Elements (KDEs)?

Critical Tracking Events (CTEs) include the following activities in the food supply chain:

  • Harvesting
  • Cooling
  • Initial packing
  • First land-based receiver (for fish)
  • Transformation
  • Shipping

Key Data Elements (KDEs) have specific requirements based on the Critical Tracking Event (CTE), but generally they must include:

  • The activity location
  • The commodity and variety (if applicable)
  • A date and reference document
  • Traceability lot codes (at Initial Packing)
  • Product descriptions (at Initial Packing)
  • Receiving
When Do I need to Assign Traceability Lot Codes (TLCs)?

Traceability Lot Codes (TLCs) are alphanumeric descriptors used to uniquely identify a traceability lot within your firm’s records. TLCs must be assigned to foods when you:

  • Initially pack a raw agricultural commodity (RAC) other than a food obtained from a fishing vessel
  • Perform the first land-based receiving of a food obtained from a fishing vessel
  • Transform a food
  • Receive a covered food from an entity that is exempt from the final rule

Once a food has been assigned a Traceability Lot Code (TLC), the Key Data Elements (KDEs) records required at each Critical Tracking Event (CTE) must include that TLC.

What About the Written Traceability Plan?

A written Traceability Plan is required for all FTL foods and must include a description of the procedures you use to maintain the required records, including the format and the location of the records. Your plan must include:

  • A description of the procedures you use to identify foods on the FTL that you manufacture, process, pack or hold
  • A description of how you assign traceability lot codes to foods on the FTL, if applicable
  • A statement identifying a point of contact for questions regarding your traceability plan and records
  • A farm map showing the areas in which you grow or raise FTL foods (other than eggs)
    • The farm map must show the location and name of each field in which you grow an FTL food, including geographic coordinates and any other information needed to identify the location of each field or growing area. This info only needs to be provided to the initial packer, and it can be a web link if applicable.
  • Regular updates as needed to ensure that your current practices are reflected and compliant with the FDA’s rules
  • Records of your previous two years of traceability plans after you update your plan
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Get on the Fast Track to Compliance with MyProduce.

MyProduce is a simple, easy-to-use and powerful software solution that helps
growers, shippers and distributors meet the newest food traceability requirements.
Run stand alone or integrated with your existing Accounting or other systems.

  • Capture, Track and Report the CTE’s and associated KDE’s
  • Scan barcodes to automatically track and validate products, linked to CTE’s and KDE’s
  • Easily print case labels in multiple formats, including Harmonized Traceability Case Labels
  • Access your software on PCs via the web or on Zebra mobile computers or tablets
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Certified and compatible for use with Zebra barcoding, label printing, and mobile computing technologies.

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Get Expert Guidance to Help with Food
Traceability Compliance.

Contact us today for expert guidance on helping your company achieve Food Traceability Compliance. We’ll help you improve inventory visibility, worker productivity and operational efficiencies along the way.

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