FDA Food Traceability Rule

FSMA Rule 204 is in effect. Your QA team needs to be ready.

FDA's Food Traceability Rule requires electronic CTE records, lot-level granularity, and the ability to respond to a trace-back request within 24 hours. Foodtrce is built to make that achievable.

Abstract representation of FSMA 204 food traceability compliance network linking lot codes through supply chain checkpoints
FSMA Rule 204 Overview

What the rule actually requires.

The FDA Food Traceability Rule (21 CFR Part 1, Subpart S) took effect in January 2026. Here's what companies on the Food Traceability List (FTL) must maintain:

01
Food Traceability List (FTL)

Over 200 food categories are on the FTL — including leafy greens, fresh tomatoes, fresh peppers, melons, herbs, shell eggs, nut butters, ready-to-eat deli salads, and fresh-cut fruits and vegetables. If your products include FTL items, you're subject to the rule.

02
Critical Tracking Events (CTEs)

You must maintain records for each CTE: initial packing, first land-based receiver (for seafood), shipping, receiving, and transformation. Each event must capture the required Key Data Elements.

03
Key Data Elements (KDEs)

At minimum: traceability lot code, quantity, unit of measure, location description, date/time, reference document type, and reference document number. Electronic format required.

04
24-Hour Response

When FDA issues a trace-back request, covered entities must provide the complete trace chain within 24 hours. Foodtrce reduces that response time to under 20 minutes.

05
2-Year Record Retention

All traceability records must be retained for two years. Records must be available to FDA upon request in a sortable, searchable electronic format — not paper or spreadsheets.

06
Traceability Lot Code (TLC)

Each entity in the supply chain must assign and maintain a traceability lot code for products on the FTL. The TLC must link to all required KDEs and flow through every CTE.

Key Dates

The FSMA 204 enforcement timeline.

November 2022
Final rule published
FDA published the final Food Traceability Rule in the Federal Register.
January 2026
Compliance date
All covered entities must be in compliance. Electronic traceability records required.
Now
Enforcement active
FDA is actively requesting trace-back records from covered entities. Is your QA team ready to respond in 24 hours?
How Foodtrce Helps

Every FSMA 204 requirement, covered.

TLC capture at every scan

Every scan event in Foodtrce captures the traceability lot code along with all required KDEs — quantity, unit of measure, location, date/time, and reference document.

CTE chain linking

Foodtrce connects receiving, processing, packing, shipping, and receiving CTEs into a single auditable chain. No manual linking required.

2-year electronic record retention

All CTE/KDE records are retained electronically for the full FSMA-required two years. Immutable audit log, searchable and exportable on demand.

24-hour response in 20 minutes

When FDA sends a trace-back request, your QA team can export the complete response report in under 20 minutes — well within the 24-hour window.

FSMA 204 enforcement is active.

Is your QA team ready for the call?

Book a 30-minute demo and see how Foodtrce connects your supply chain into a FSMA 204-compliant trace system.