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The clock is ticking for the food industry as it approaches the January 2026 deadline for compliance with FSMA 204, the U.S. Food and Drug Administration's (FDA) Food Traceability Rule. Released in November 2022, the regulation is designed to improve recall precision, speed, and scope by requiring companies to enhance their traceability practices for high-risk foods. With its call for increased data sharing across supply chains, it represents a landmark step toward a safer food system. 

Much progress has been made thus far on the road to compliance; however, significant challenges remain. These challenges underscore the complexities involved in transforming the food supply chain into a more transparent and resilient system. Below are some of the gains and growing pains on the traceability landscape as companies head into the home stretch of FSMA 204 compliance: 

  • Increased need for federal funding. The FDA has played an active role in preparing the industry for compliance. A robust library of guidance documents, FAQs, and other resources has been developed, and agency staff have attended industry events and conferences to engage directly with food system stakeholders. On the FDA’s behalf, the Reagan-Udall Foundation has held roundtables with industry members to share insights, identify and prioritize key issues, and explore implementation strategies. Despite these efforts, however, awareness and readiness across the food industry are uneven. Many companies, particularly smaller ones, still grapple with the demands of meeting the Traceability Rule’s requirements. The FDA’s ability to offer further support is constrained by limited funding, leaving gaps to fill as the deadline looms. 
  • Distributors’ data hurdles. Large retailers, including Kroger and Walmart, have taken proactive steps by mandating traceability compliance across their supplier networks. In some cases, these go beyond the FDA’s requirements and signal the growing commitment to the idea that comprehensive traceability is critical to ensuring food safety. However, many distributors face formidable hurdles, such as upgrading warehouse management systems to capture the required key data elements (critical information related to a food’s path along the supply chain) or adopting new technologies for seamless data exchange. A lack of standardization in data formatting and sharing has further complicated these efforts creating inefficiencies and raising costs for supply chain participants. 
  • The interoperability conundrum. The Traceability Rule outlined which data needs to be collected and when, but it opted not to outline how that data should be formatted and shared. While some companies have implemented efficient traceability systems, interoperability between different platforms remains a persistent challenge. Established data standards, such as those maintained by GS1 and commodity-specific applications of those standards, such as the Global Dialogue on Seafood Traceability Standard, provide a foundation for interoperable data exchange in food supply chains, but without industrywide standardization, data roadblocks and vendor lock-in hinder progress. Technology providers have stepped in to offer solutions, but the landscape remains uneven.  

The way forward 

Although the journey toward full traceability is fraught with challenges, it’s important not to lose sight of the progress made. 

During the past two years, advocacy groups and industry associations have played a vital role in fostering compliance. Sector-specific initiatives, such as the Produce Traceability Initiative and the National Fisheries Institute, have provided tailored resources and facilitated partnership among stakeholders. Broader coalitions like the Food Industry FSMA 204 Collaboration—comprised of leading food industry groups, including IFT’s Global Food Traceability Center (GFTC)—have formed to unify efforts across sectors, offering educational materials and promoting best practices. 

Media coverage of high-profile recalls has kept food safety firmly in the public spotlight, fueling renewed energy around the need for a safer, more transparent, and more accountable food supply chain. And as awareness grows, traceability has become a focus not just in food industry circles, but beyond. Over the past two years, GFTC has engaged nearly 20 different government agencies globally to talk about traceability and its various applications, from Illegal, Unreported, and Unregulated [IUU] Fishing to the EU’s deforestation regulation.  

As the countdown to FSMA 204 compliance marches on, the food industry must continue to double down on efforts to achieve its promise. The compliance period has elevated the conversation and inspired action. There’s no turning back. And that, in and of itself, is progress.   

To learn more about the FDA’s Traceability Rule and steps to take to achieve compliance, view IFT’s commodity-specific food traceability videos; read an analysis of the rule in this IFT white paper; and join industry experts on January 31, 2025, at 2 p.m. EST for an informative webinar on FSMA 204 compliance, sponsored by the Food Industry FSMA 204 Collaboration. 

Sara Bratager is senior food traceability and food safety scientist with IFT’s Global Food Traceability Center (GFTC).

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