Beginning Jan. 20, 2026, FDA will require everyone who manufacturers, processes, packs or holds certain foods to meet new traceability requirements, including maintaining key data elements associated with specific critical tracking events – such as harvesting, cooling, packing, shipping and receiving – that can be provided quickly to FDA when requesting to assist with a recall or managing a threat to public health.
To comply, industry stakeholders will need to work with supply chain partners to develop traceability plans that assign and track traceability lot codes to high-risk products included on FDA’s Food Traceability List.
“By requiring the sharing of product traceability information between members of the industry, and between industry and the FDA, that have not been required in the past, firms must establish new communication platforms as well as implement significant changes to processes and procedures. There is a degree of complexity to implementation, and even more so, for those foods that pass through many hands between the farm and the point of sale,” FDA Deputy Commissioner for Human Foods Jim Jones acknowledged at a recent public meeting hosted by the Reagan-Udall Foundation.
He added, “There is no question that this is a heavy lift, but this is a rule whose time has come. For each foodborne illness outbreak, by meeting this rule’s requirements, we will be able to remove contaminated foods more swiftly and efficiently from the marketplace. This will allow us to improve public health through the prevention of illness and death, as well as prevent the tremendous waste that results from recalls that are overly broad.”
Manufacturers, retailers, growers and restaurateurs at the meeting all agreed with the rule’s intent and benefit – but they also vented about the myriad means to the end, interoperability challenges and confusion or inconsistency around which foods and products need to be tracked as part of the rule.
The answer to these frustrations is increased collaboration – but as those gathered by the Reagan-Udall Foundation noted, that may be easier said than done.
‘Too many portals, too many integration points is going to be untenable’
A natural response when creating new processes and communication frameworks, like those required of FDA’s impending Food Traceability Rule, is to explore and adopt new technologies that promise to streamline data management and sharing.
But Johnny McGuire, the chief operating officer at Producesupply.org, urges stakeholders to think first about how existing frameworks could be used and think twice before adopting new technologies.
“Although this is an opportunity to apply technologies and new technologies, we want to be careful with too much of that. As an IT manager with that hat on, we have got a lot of different requests coming in from trading partners for different integration points,” he said. “Too many portals, too many integration points is going to be untenable for us.”
Likewise, the window for adopting internal processes to comply to different external technology platforms is running out and the costs are running up, added Jodi Blanch, senior quality assurance manager at Gordan’s Seafood.
“Some retailers are demanding that suppliers, like Gordan’s, use specific third-party software to transmit the key data elements. Each software platform has their own cost, often large, and their own way of accepting the data. At this time, many of the third-party software platforms are not able to accept the same data in the same format, meaning that we will have multiple systems, yet to be determined, or have to manipulate the data differently for each of these third party platforms,” she explained.
External costs could slow internal updates
Investing in external technology requirements is a tall order given that many companies are grappling with their own internal IT shortcomings, she added.
“Most current IT systems, including warehouse management systems, are older and either need to be updated, if that is even possible, or scrapped,” she said.
She shared an example of an “IT glitch” due to outdated systems that recently occurred at Gordan’s: The company wanted to use the 13-digit global location numbers as its traceability lock code source, required by the law, but its existing system can only handle eight digits.
“Rather than going berserk with all these new technologies – RFID, that kind of thing – let's use what we have got,” said McGuire. He noted existing frameworks could hold the solution – especially when a shared language is created between stakeholders.
He added what matters more than the system is that the structure of the data is “right” and consistent among players, which will require collaboration and open communication.
Blanch: Start with FDA’s Food Traceability List before adding more products
Stakeholders also need to work together to agree on application parameters – including which foods and products need to be tracked, said Blanch.
An obvious answer would be just the products included on FDA’s Food Traceability List, but Blanch said some retailers are expanding the list to include all foods — creating an added burden at a time when some players are struggling to meet the basics.
“We have been notified by two large retailers that they are mandating key data elements for all foods – foods like pickles, chips, pretzels and salad dressings, not just the ones on the FDA Food Traceability List. I am sure this was not FDA’s intention,” she said.
“This extra demand by some of the retailers is putting resources and money where it is not needed. These retailer requests are coming in late and now companies that thought they were exempt are not, at least by the retailer standards. And to add further complication, these retailers are demanding earlier compliance timing date than the FDA of January 2026,” she explained.
A staged-approach would ensure all stakeholders are on the same page
Rather than trying to do everything at once, stakeholders should collectively agree on a collaborative “staged approach” to complying with the rule, offered Lindy Wiedmeyer, food safety manager with Sendik’s Food Market.
“Collaboration is a huge part of anything for us in food safety and working to make sure we are putting out safe food – whether starting with a grower or restaurant or a grocery store. And I think a good place to start is doing a staged approach,” she said.
“You cannot start something right in the middle and expect everybody to adapt. Starting from the beginning and working our way forward, it helps us take into account all the numerous amount of variables that are going to show up with either certain suppliers using a UPC code or a QR code or any means to import their data into that information or in that little data that they put on their shipments,” she said.
Pen and paper processes pose data integrity challenges
This also would create space to account for many processes that currently are executed with pen and paper, and for which a rushed change could result in errors and increased fragility, said McGuire.
“We are relying on very much paper-based systems. Now when a product shows up at our distribution centers, at our coolers, the information we are getting is a piece of paper, that has probably been poorly written and probably could have errors on it, and now my receivers have got to … take that information, store it in our system and then pass it forward to our trading partners. I have a concern about” data entry errors, and wonder “are we making the traceability a little more fragile there?” he explained.
Avoiding data and communication errors will require more time and money to create or update systems and test them before going live, Blanch said. She explained this is why she believes “the greatest need for collaboration that will make the most difference is on the IT technology side” and focusing first on what FDA requires and adding extra components later as able or warranted.
