Turn a 24-hour traceback into a query — FSMA 204.
The deadline moved to 20 July 2028, but the data plumbing across your trading partners is what takes the time. This checklist covers Critical Tracking Events, Key Data Elements, lot codes, and the sortable spreadsheet FDA can ask for at any moment.
The compliance date was extended by 30 months to 20 July 2028 (FDA, Aug 2025; made binding by Congress in Nov 2025). The extra runway is for building the data plumbing across thousands of partners — starting now leaves time to finish.
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When is the FSMA 204 compliance date?
The Food Traceability Rule compliance date was extended by 30 months to 20 July 2028 (FDA, August 2025; made binding by Congress in November 2025).
What does FSMA 204 require?
Firms handling Food Traceability List foods must keep records of Key Data Elements for Critical Tracking Events — harvesting, cooling, initial packing, shipping, receiving, and transformation — maintain a Traceability Plan and Traceability Lot Codes, and provide a sortable electronic spreadsheet to FDA within 24 hours of a request.
Who must comply with FSMA 204?
Any firm that manufactures, processes, packs, or holds foods on the FDA Food Traceability List, subject to certain exemptions for some small producers and specific retail and food-service situations.
The checklist tells you what. We show you how.
A fixed-fee, 14-day Aeroz audit maps your own products against this checklist — a written gap analysis, with no commitment to proceed.