The FDA and USDA announced nearly 300 food recalls in 2024 — that’s hundreds of manufacturers who had to scramble, often under intense scrutiny, to trace contaminated products back to their sources and pull them from shelves before they reached more dinner tables.
Food traceability may be the backbone of modern food safety, but building a robust traceability system is easier said than done, thanks to layers of regulations, patchwork supplier data, and complex supply chains. Unsurprisingly, even the most well-prepared teams can find themselves caught in a logistical nightmare during a recall.
So, what does it actually take to improve traceability in the food supply chain? Read on as we break down the most common roadblocks manufacturers face and the strategies that can make traceability more manageable right from the start.
What are some common food traceability challenges?
Traceability in the food supply chain may sound simple in theory: Track ingredients from source to shelf. But in reality, it’s a process riddled with hurdles, like:
- Lack of standardization: Although the FDA’s final rule of the Food Safety Modernization Act (FSMA) mandates that manufacturers maintain a food traceability plan (including procedures for maintaining records, a list of FLT foods handled, and contact information for responsible personnel), it doesn’t specify a required format. That means every company is left to interpret the rule in its own way. The result is a patchwork of systems, formats, and processes that don’t always line up, even across the same supply chain.
- Additional requirements for certain ingredients: If your product includes anything from the FDA’s Food Traceability List (e.g., leafy greens, soft cheeses, or shell eggs), you must follow even stricter documentation rules. Not only must you record Key Data Elements (KDEs) for each Critical Tracking Event (CTE), but you’re also required to hand over that data within 24 hours if the FDA asks. CTEs include key points in the product’s journey, like harvesting, cooling, initial packing, first land-based receiving, shipping, receiving, and transformation. That’s a lot of checkpoints to monitor across a complex supply chain.
- Complicated supply chains: Few food manufacturers have the luxury of a single-source operation. Instead, ingredients and products move through a tangled network of growers, packers, processors, shippers, and distributors, each with their own systems, data formats, and timelines. In other words, to trace a single batch, you may need to pull data from a dozen different sources, cross-reference KDEs across multiple partners, and connect the dots across transformations, shipments, and handoffs.
- Data overload and siloed systems: Tracking every ingredient and transformation across the supply chain generates a massive amount of data. It’s easy to overlook crucial details or lose track of documentation altogether.
- Data privacy: Under FSMA, manufacturers are required to provide complete traceability records to the FDA upon request. Meeting that obligation often means gathering sensitive information from suppliers and partners, like sensitive trade secrets and personal data. Yet, without the proper safeguards in place, suppliers may be reluctant to provide the details you need.
How to Improve Traceability in the Food Supply Chain
Identify FTL ingredients early on
If you're working with ingredients on the Food Traceability List (FTL), you already know about the more stringent documentation requirements.
To make sure your team doesn’t end up scrambling in a recall scenario, consider building FTL awareness into your workflows from the ground up. Follow these steps:
- Add FTL checks to early-stage workflows. Whether you’re developing a new product, sourcing ingredients, or onboarding a new supplier, make verifying FTL status a requirement. Cross-reference every ingredient against the FDA’s list and document the result.
- Maintain a master list of FTL ingredients across SKUs. Don’t let this live in someone’s inbox. Keep an up-to-date list of all FTL ingredients your facility handles and make it accessible to teams across R&D, procurement, QA, and operations.
- Tag FTL ingredients clearly in your systems. Use your ERP or inventory management software to flag any SKU that contains an FTL item. This alerts your team in real time when additional traceability actions are needed.
- Build a dedicated traceability protocol for FTL items. Traceability records must be electronic and sortable under FSMA. So, create a parallel process for handling FTL ingredients, from custom forms and digital checklists to automated data capture points that track KDEs at every CTE.
Prioritize collaboration and relationships
Traceability in the food supply chain is a team effort that spans departments, vendors, and supply chain partners. Use these tips to make collaboration a core part of your traceability plan:
- Start with your internal team. Build a cross-functional group that includes QA, operations, procurement, IT, and anyone else involved in sourcing, tracking, or reporting. Assign clear ownership: Who’s responsible for ingredient-level traceability? Who updates KDEs? Who leads vendor communication in the event of a recall?
- Map your supplier and vendor network. Create a detailed list of every external partner in your supply chain. Then, establish formal tracking protocols: What data needs to be shared? How often? In what format? Establish expectations and confirm agreement upfront, revisiting those expectations regularly to keep things aligned.
- Implement shared systems (not shared assumptions). Verbal agreements and email chains won’t cut it. Invest in digital tools like supplier portals or ERP-integrated traceability modules that make it easy for partners to submit data, flag issues, and sync with your internal team.
- Make transparency the default. Trust is built through clarity. When partners know what’s expected and can see their role in the bigger picture, they’ll be more likely to follow protocols and flag potential issues early.
Invest in digital tools
Manual record-keeping might have worked when operations were smaller, but today’s supply chains are too complex and fast-moving for clipboards and spreadsheets. Luckily, digital tools make it possible to operate more efficiently at scale.
The key is building the right tech stack for your operation. Here’s where to start:
- Enterprise resource planning (ERP) systems: ERPs gather and combine data from across your organization (e.g., inventory, production, distribution, and QA), making them a powerful backbone for traceability in the food supply chain. It’s no surprise that ERP is projected to see the fastest growth in the food traceability market of any software, with a forecasted CAGR of 10% through 2030.
- Traceability or supply chain management software: These platforms are purpose-built for food traceability, allowing you to track CTEs and KDEs in real time across vendors, with automated alerts for compliance gaps or missing data.
- Cloud-based collaboration platforms: Tools like Trello, Slack, or supplier portals within your ERP can streamline communication between internal teams and external partners. Everyone stays aligned, updates are documented, and nothing slips through the cracks.
Bring in external expertise to fill knowledge gaps
Even the most experienced teams run into blind spots, especially when regulations evolve or supply chains become more complex. That’s where outside support can make all the difference.
Whether you need help clarifying FSMA requirements, fine-tuning your recall workflow, or building a traceability plan from the ground up, partners like AIB International can save your team hours of trial and error. With decades of food safety experience, we turn regulatory language into practical, on-the-ground strategies.
If you're looking to level up your traceability plan or simply ensure you’re audit-ready, AIB International’s Traceability and Recall for Food & Beverage course is a great place to start. Sign up today.
