Every food retailer, wholesaler, manufacturer and supplier has found themselves in the middle of the largest supply chain data collaboration project in history. Under the FDA’s final rule on food traceability (FSMA 204), additional traceability recordkeeping is required every time foods like tomatoes, all types of peppers, soft cheeses, nut butters, certain seafoods – and more – change hands or change form.
The FDA’s rule is complex, as is the data requirement, but the nation’s top grocery retailers and wholesalers are taking traceability a step further, requiring more data for more foods in less time when compared to the FDA. Now, the industry’s trend toward traceability is driven just as much by the competition as it is by the legal and regulatory threats presented by the FDA law.
What are major retailers and wholesalers doing about traceability?
Within the last few months, major retailers – including Kroger, Walmart and Target – have communicated publicly about traceability, outlining specific requirements for their suppliers. To further their commitments to food safety and transparency within their supply chains, these retailers and others have tailored their traceability programs to the needs of their businesses, including:
- Adding full categories or in some cases ALL FOODS to their traceability program, rather than the subset of foods included on the FDA’s Food Traceability List (FTL).
- Requiring more data elements (referred to by the FDA as “Key Data Elements” or “KDEs”).
- Establishing a deadline that is earlier than the FDA’s enforcement deadline of January 20, 2026.
Not only have these major retailers already launched their traceability programs, they’ve established programs that are more robust than the FDA’s. Suppliers are already beginning to enroll and onboard, and consumers are taking notice.
In that regard, pressures from inside the industry have increased in intensity. The issue for other retailers and wholesalers now becomes competitive in nature. Will consumers want to shop a brand that can’t do – or won’t do – traceability? Probably not. As an operator, would you want to explain to your CEO why your company can’t do – or won’t do – traceability while your competitors are well on their way? Probably not.
Do suppliers have the technical capabilities to do traceability?
Up to 70% of suppliers do not have an Information Technology (IT) department or the general technical support staff to help with the data exchange required for traceability. In addition to the technical challenges, suppliers are also faced with fulfilling a different set of data requirements for each customer they serve. For many suppliers, traceability may be an impossible task without help from the right technology partner.
What data needs to be shared?
Some but not all traceability data can be printed on the label. That’s because only some but not all traceability data is available when the label is printed. This traceability data instead needs to be sent electronically for EVERY shipment, and then combined with data from the label to form a complete traceability record.
Where does the remaining traceability data come from?
Most often suppliers already have this information within documentation like Advanced Shipping Notices (ASNs), Bills of Lading (BOLs) or within existing systems like a Warehouse Management System (WMS) or accounting system. It’s just a matter of extracting and sharing that data every time a shipment is sent.
Learn more by watching this video about why labels won’t do traceability, by themselves.
Is there still time to start a traceability program?
The enforcement deadline from the FDA is just over a year away. The first strategic step that retailers and wholesalers need to take is making contact with suppliers and creating connections. That means you’ll need to:
- Determine and document your traceability requirement, ensuring that at the very least, your program meets the requirements of FSMA 204.
- Review each supplier’s product list to determine which foods and SKUs appear on the FTL.
- Contact each supplier to:
- Explain the FSMA 204 food traceability final rule as well as any additional traceability requirements that your company has established. Answer any questions or address any issues that are specific to their unique operations.
- Identify what traceability data elements (KDEs) are required and help them to find the data within their existing labels, systems and documentation.
- Establish your requirements for data formatting and communication and test with each supplier.
- Create an error identification and correction process for when data is missing or incomplete, and ensure that each supplier understands how to make corrections.
Traceability comes with its advantages. Having the data and increased visibility into your supply chain creates the opportunity for efficiencies in backdoor receiving, invoice reconciliation and accounting, and even inventory and waste management. There is a tremendous amount of pressure to meet – or even exceed – the requirements of the FDA’s FSMA 204 food traceability law.
The ReposiTrak Traceability Network® was designed with guidance from grocery retailers and industry organizations to be a fast, easy-to-use and incredibly inexpensive food traceability solution. These have been our guiding principles and we’re true to it.
If you’re interested in learning more about how ReposiTrak can help, please contact ReposiTrak today.
