FDA Food Traceability Rule · foods on the Food Traceability List · compliance date extended to 20 July 2028.
The FDA's Food Traceability Rule requires anyone who manufactures, processes, packs or holds foods on the Food Traceability List — leafy greens, fresh-cut fruit and vegetables among them — to keep Key Data Elements for defined Critical Tracking Events, and hand FDA a sortable spreadsheet within 24 hours of a request. The compliance date has been extended to 20 July 2028; the recordkeeping build takes most companies longer than they expect.
A written plan describing how you assign traceability lot codes, where records live, and who FDA calls — the document an investigator asks for first.
Harvesting, cooling, initial packing, shipping, receiving, transformation: each Critical Tracking Event carries its Key Data Elements, linked by the traceability lot code.
The traceability lot code must persist as produce moves and transforms — the single thread FDA follows from a case of illness back to a field.
On request, records must reach FDA as an electronic sortable spreadsheet within 24 hours. Paper in a filing cabinet fails this test by construction.
FDA extended the compliance date to give the supply chain time to build. Retail buyers are not waiting — major retailers already push FSMA-grade data requirements into their produce suppliers.
Walk product from field to dock and list every event the rule defines. Most gaps hide at cooling and transformation, not at shipping.
A lot code that lives on a carton sticker and a clipboard will not survive a 24-hour spreadsheet request. Capture it electronically at every hop.
Pick a shipped lot at random and produce the full CTE/KDE chain within 24 hours. If the rehearsal fails, the real request will too.
Aeroz carries the traceability lot code on a chip-read carrier at case or pallet level, so every CTE writes itself as an EPCIS 2.0 event on a scan — harvest to cooler to packer to DC. The 24-hour spreadsheet becomes an export, recalls narrow from "all romaine" to specific lots on specific pallets, and the same record answers the retail buyers already demanding it.
Foods on FDA's Food Traceability List — including leafy greens, fresh-cut fruits and vegetables, cucumbers, herbs, melons, peppers, sprouts and tomatoes. If you grow, pack, process or hold them, the rule reaches you.
FDA extended the compliance date to 20 July 2028 for the recordkeeping requirements. Large retail buyers are already imposing equivalent data requirements ahead of the date.
The identifier you assign that links every Critical Tracking Event for a lot — assigned at initial packing or transformation and carried through the chain. It is the thread FDA pulls in an outbreak.
No — the rule requires records, not a specific technology. Chips are how the records write themselves: scan-based capture beats clipboard-based capture on accuracy, speed and the 24-hour test.
A fixed-fee Aeroz audit maps your products against fsma 204 for produce requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.