FDA Food Traceability Rule · nut butters on the FTL · transformation-heavy chains · compliance 20 July 2028.
Nut butters earned their Food Traceability List spot the hard way — some of the largest Salmonella recalls in US history ran through peanut butter, with contaminated lots spread across hundreds of downstream products. FSMA 204 requires processors and brands to keep transformation-linked lot records so the next event traces in hours, not weeks.
Raw nuts into butter is a transformation CTE: new traceability lot codes linked to input lots, batch by batch.
Nut butter becomes an ingredient in bars, snacks, sauces. Your ship records are the map regulators use to find every downstream product touched by a lot.
Raw nut receipts with lot-level KDEs anchor everything — a blind receipt makes every batch after it untraceable.
Electronic, sortable CTE/KDE records to FDA within 24 hours — for a category where the request has historically come with national attention.
Compliance is 20 July 2028. Brands buying nut butter as an ingredient are already demanding lot-linked data from processors, because their own FTL exposure depends on it.
Every inbound raw-nut lot captured electronically with its KDEs — the foundation the grind records build on.
Batch records linking input lots to output lots, captured at the line — this is what turns a national recall into a targeted one.
Know which customers took which lots within an hour. Your customers' recalls start with your shipping records.
Aeroz binds lot identity to totes, cases and pallets with chip carriers, writing receipts, transformations and shipments as EPCIS 2.0 events. When a lot goes bad, the system answers the two questions that matter — what went into it, and where did it go — in minutes, with a log a regulator can audit.
Yes — nut butters are an FTL category, covering the processors who make them and the supply chain that handles them.
The FTL entry covers the nut butter itself; finished products containing it as an ingredient are generally outside the FTL — but your customers still need your lot data when their product is implicated, which is why buyers demand it contractually.
The transformation genealogy — which raw-nut lots went into which finished batches. Kept at the line it is trivial; reconstructed after an event it is guesswork under pressure.
20 July 2028 under the FDA's extension, with commercial pressure from ingredient buyers arriving well ahead of it.
A fixed-fee Aeroz audit maps your products against fsma 204 for nut butters requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.