Food traceability standards can feel like a moving target. The FDA’s Food Traceability Rule has a longer proposed enforcement timeline than originally planned, but that doesn’t mean food suppliers should wait to act.
Overseeing bodies like the FDA aren’t the only entities with high traceability standards. Retailers have their own expectations — and many are pushing for faster implementation, broader product categories, or more stringent documentation than federal requirements.
For food suppliers and manufacturers, maintaining these crucial partnerships under increasing pressure is paramount. Discover why many retailers are cracking down on traceability requirements, how to evaluate where you stand, and strategies to meet expectations and remain a partner retailers can trust.
Under the FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods, businesses that manufacture, process, pack, or hold foods on the FDA's Food Traceability List (FTL) must be prepared to update their food supply chain traceability practices to meet new standards by the FDA’s proposed deadline extension, July 20, 2028.
Specifically, applicable businesses must maintain records containing Key Data Elements (KDEs) associated with specific Critical Tracking Events (CTEs). These events include:
Harvesting
Cooling (before initial packing)
Initial packing
First land-based receiving
Shipping
Receiving
Transformation
The exact KDEs that businesses are required to track will vary depending on their relevant CTEs. Regardless of which KDEs you record, all records must be made available to the FDA within 24 hours or a reasonable, agreed-upon time.
FSMA 204 also requires businesses to apply traceability lot codes (TLC) to records regarding certain food products, maintain a compliant traceability plan, and meet other specific recordkeeping formatting requirements.
These FDA updates align with current industry best practices, and the new guidelines apply to domestic and foreign firms that produce food products sold in the U.S. These rules are designed to help businesses and regulators alike more rapidly identify potentially contaminated products and remove them from the market to reduce foodborne illnesses among consumers.
This rule initially had a compliance date of January 20, 2026, but industry-wide concerns about implementation timelines led the FDA to propose a deadline extension to better accommodate the work required to update businesses’ traceability practices. Regardless, manufacturers don’t necessarily have the luxury of waiting; some major retailers aren't treating the FDA’s extension as a reason to slow down, and many are instead holding their partners to even stricter traceability expectations.
For grocers, FSMA 204 is only the first step; true traceability requires more due diligence to effectively protect their brand reputation and maintain customer loyalty. After all, retailers are the last touchpoint before consumers take products home. When a customer contracts a foodborne illness from a product they bought at the store, the retailer is often the face of that purchase.
This responsibility means that in the event of an outbreak, involved retailers can expect to see their names in news reports, face uncomfortable questions, and take reputational hits. In an effort to mitigate these risks, major retailers are making independent adjustments to their internal traceability requirements among their supply chain partners as a precautionary measure.
Many of these independent food traceability requirements impose even stricter standards than the FDA in two key ways: product scope and timeline. Large retailers such as Albertsons, Sam’s Club, KeHE, Kroger, Walmart, and Target, for instance, are requiring traceability records for all food products — not just those listed to the FTL.
For manufacturers, this sweeping requirement may actually simplify the traceability process in some ways. Rather than creating separate recordkeeping procedures for only certain products, manufacturers and other stakeholders along the supply chain can apply changes across the board for better consistency and less confusion.
Some grocery stores — such as Aldi, H-E-B, Meijer, Publix, and Wegmans — are also reportedly asking their partners to meet traceability requirements sooner than the FDA's FSMA 204 deadline. For suppliers who have yet to update their traceability practices, either because FDA enforcement is delayed or because they don't produce FTL products, this vendor-level change could come as a shock.
Adapting programs doesn't happen overnight, and businesses with limited flexibility or technical adaptability could be in for a challenge if they don't reconsider their traceability practices sooner rather than later. Ultimately, requirements will vary by retailer, supplier category, product type, and other factors, so communicating with your partners and aligning your traceability system to their expectations is crucial.
These new traceability standards vary from retailer to retailer — with some major chains taking more drastic measures than other smaller businesses. So how do you know whether you can meet the traceability expectations of the retail partners that carry your product?
Use these strategies to determine whether you’re prepared to meet advanced food traceability requirements (and identify where you may need to pivot):
Review your partners’ standards: Before you make any adjustments to your current practices, determine what’s expected of you. Do you need to track all food products or just those on the FTL? When is your deadline to comply? What are your data requirements? Aligning with retail partners on these foundational questions is a vital first step.
Be proactive in your traceability adjustments: Don't wait to make traceability updates just because the FDA has shifted its timeline. Beginning the process now will allow your operations more time to implement changes and smooth out any bumps along the way. With a proactive approach, you’ll save your team the stress and headaches of major change and ensure your operations meet your partners’ food traceability timeline.
Educate your team on the latest standards: Updates made at the top must be effectively communicated to your frontline workers. This means administering updated traceability training that accounts for new standards and ensuring competency with the new system using methods like surveys and assessments.
Evolve your recordkeeping practices: A key update to both the FDA and many retailers’ traceability standards is more extensive recordkeeping. Confirm whether your current system can capture, store, link, and share KDEs by lot, shipment, and trading partner. Evaluate whether you're following documentation best practices with standardized log structures, clear ownership, and consistent formatting. Optimizing your recordkeeping will help you respond to retailer data requests while also enhancing your efficiency and food safety efforts.
Work with traceability experts: Sometimes an outside perspective can help you see where your traceability system is falling short. Bringing in a food safety expert with experience in traceability can help you streamline your program to reduce headaches, meet requirements more quickly, and adjust your practices sustainably.
Evaluating early can help you stay agile and maintain positive relationships with your retail partners. By demonstrating a commitment to traceability, you’ll show your partners that you are equally dedicated to them as they are to you – encouraging future business and stronger trust between your organizations.
Meeting FSMA 204 requirements won’t be enough to maintain your retail partnerships (or encourage new ones). Retailers are holding their suppliers accountable for tracking products with greater speed, consistency, and precision. That's why you can't risk gaps in your traceability practices.
Partnering with experts can help you get your traceability program where it needs to be to meet market pressure. With AIB International, you can work with an expert consultant to evaluate where your traceability measures may be falling short of industry expectations and take actionable steps to remedy them.
Afterward, enroll your frontline team in AIB International’s Traceability and Recall Online for Food & Beverage course to ensure they’re on the same page and ready to execute your new standards.