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FDA Food Traceability Rule · checked 23 October 2026

FSMA 204: records within 24 hours. No enforcement before 20 July 2028.

The FDA's Food Traceability Rule (21 CFR Part 1, Subpart S) requires anyone who manufactures, processes, packs or holds a food on the Food Traceability List to keep key data at each step and hand it to FDA within 24 hours of a request.

  • FSMA 204 · THE CLOCK
  • Jan 2023final rule in force
  • 20 Jan 2026original date
  • 20 Jul 2028earliest enforcement
  • 24 hoursto answer FDA
  • Congress directiveFDA complies
Checked 23 October 2026

Where it stands.

Each line names the source it was checked against.

Compliance date
FDA will not enforce the rule before 20 July 2028. FDA proposed a 30-month extension and Congress then directed it not to enforce before that date; FDA says it intends to comply. FDA
Who it covers
Anyone who manufactures, processes, packs or holds a food on the Food Traceability List, including foods that contain a listed food as an ingredient, with some exemptions. 21 CFR 1.1300–1.1465
Records
Traceability records go to FDA within 24 hours of a request, or a reasonable time FDA agrees to. In an outbreak or recall, FDA can ask for an electronic sortable spreadsheet. 21 CFR 1.1455
Plan
Each covered firm keeps a written plan: how its records are kept, how it identifies foods on the list, how it assigns lot codes, and a contact. 21 CFR 1.1315
The rule

What to record, and when.

  • Critical tracking events

    Harvesting, cooling, initial packing, first land-based receiving for seafood, shipping, receiving and transformation.

  • Key data elements

    For each event: the traceability lot code, the food, the quantity, the locations involved and the date, plus the reference document.

  • Traceability lot codes

    Assigned at initial packing, first land-based receiving or transformation, and passed along with the food so the next firm can record it.

  • Technology-neutral

    Paper, spreadsheets or software all count. What counts is producing the records in 24 hours, in a sortable form when FDA asks.

Where Aeroz fits

How Aeroz answers FDA in hours, not days.

  • One record per lot

    Every critical tracking event becomes a signed, timestamped entry against the lot, in GS1 EPCIS 2.0, so nothing is rebuilt from invoices.

  • The spreadsheet, on demand

    The sortable spreadsheet FDA asks for comes straight out of the event log for any lot, date range or location.

  • A narrower recall

    Unit- and lot-level records show exactly which product touched the suspect lot, so a recall can be sized to it.

Questions

FSMA 204, answered.

When is the FSMA 204 compliance date?

FDA will not enforce the Food Traceability Rule before 20 July 2028. The original date was 20 January 2026; FDA proposed a 30-month extension and Congress directed it not to enforce before July 2028.

Which foods are covered?

Foods on FDA's Food Traceability List, such as soft cheeses, shell eggs, nut butters, leafy greens and other fresh produce, fresh-cut fruit and vegetables, finfish, crustaceans, molluscs and ready-to-eat deli salads, plus foods that contain them as an ingredient.

How fast do records have to reach FDA?

Within 24 hours of a request, or a reasonable time FDA agrees to. In an outbreak, recall or other threat to public health, FDA can ask for an electronic sortable spreadsheet.

Does FSMA 204 require RFID or chips?

No. The rule is technology-neutral. It asks for key data elements at critical tracking events and the ability to produce them on time.

Sources: FDA: FSMA final rule on traceability records · 21 CFR Part 1, Subpart S. Checked 23 October 2026. Not legal advice.

Key facts · FSMA 204

The FDA Food Traceability Rule (FSMA section 204) covers foods on the Food Traceability List. FDA will not enforce it before 20 July 2028. Records go to FDA within 24 hours of a request.

Rule
21 CFR 1 Subpart S
Enforcement
20 Jul 2028
Response
24 hours
Format
sortable spreadsheet