FDA Food Traceability Rule · shell eggs on the FTL · initial packing is the anchor event · compliance 20 July 2028.
Shell eggs sit on the Food Traceability List, and the egg chain's speed is exactly why: eggs move from layer house to carton to shelf in days, and an outbreak traceback has to move faster. FSMA 204 anchors the record at initial packing — where the traceability lot code is born — and requires every handler after that to keep the chain intact.
The traceability lot code is assigned when eggs are initially packed — tied to the farm, house and pack date that produced them.
Packers, distributors and receivers each record their Critical Tracking Events with the lot code carried through — repacks included.
The pack record must resolve back to the supplying farm and house — the data FDA actually needs in a Salmonella traceback.
The standard FTL duty: a sortable electronic spreadsheet of the relevant records to FDA within 24 hours of request.
Compliance is 20 July 2028. Egg recalls are among the largest and fastest-moving in food — the operational payoff of clean lot data arrives with the first event, not the deadline.
Assign and capture lot codes electronically at the grader/packer — the single point where the whole chain's data quality is decided.
Eggs get repacked and consolidated; each event must link new lots to source lots or the trace dies mid-chain.
Pick a carton in a store, walk it back to the layer house on paper. Time it. That number is your real readiness.
Aeroz carries the traceability lot code on chip carriers at case and pallet level, writing packing, shipping and receiving CTEs as EPCIS 2.0 events automatically. In an event, the recall narrows from 'all eggs from the plant' to specific lots on specific pallets at specific stores — which is the difference between a bad week and 19 million eggs destroyed.
Shell eggs are on the Food Traceability List. Egg products (liquid, frozen, dried) are regulated separately and are not the FTL entry — the carton in the dairy case is the covered item.
At initial packing. The packer assigns it and ties it to source farm and house data, and everyone downstream carries it.
Repacking is a new event with new lot linkage — the new lot must reference the source lots so the chain stays walkable in both directions.
Because eggs turn over in days and outbreaks compound daily. A traceback that takes two weeks means product is eaten before it is found; lot-level data makes the answer same-day.
A fixed-fee Aeroz audit maps your products against fsma 204 for shell eggs requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.