FSMA 204 for nut butters.
FSMA 204 for nut butters is the part of FDA's Food Traceability Rule that covers nut butters, with transformation records linking each finished lot to the lots of nuts that went into it.
Nut butters earned their Food Traceability List spot the hard way — some of the largest Salmonella recalls in US history ran through peanut butter, with contaminated lots spread across hundreds of downstream products. FSMA 204 requires processors and brands to keep transformation-linked lot records so the next event traces in hours, not weeks.
FSMA 204 for nut butters, in three facts.
FDA Food Traceability Rule · nut butters on the FTL · transformation-heavy chains · compliance 20 July 2028.
Nut butters are on FDA's Food Traceability List.
Source: FDA, Food Traceability ListFDA will not enforce the Food Traceability Rule (FSMA section 204) before 20 July 2028.
Source: FDA, FSMA final rule on traceability recordsFirms covered by FSMA 204 must give FDA their traceability records within 24 hours of a request, as an electronic sortable spreadsheet in an outbreak or recall.
Source: 21 CFR Part 1, Subpart S
One contaminated lot, a hundred products.
Transformation records at the grind
Raw nuts into butter is a transformation CTE: new traceability lot codes linked to input lots, batch by batch.
Fan-out visibility
Nut butter becomes an ingredient in bars, snacks, sauces. Your ship records are the map regulators use to find every downstream product touched by a lot.
Supplier lot discipline
Raw nut receipts with lot-level KDEs anchor everything — a blind receipt makes every batch after it untraceable.
The 24-hour spreadsheet
Electronic, sortable CTE/KDE records to FDA within 24 hours — for a category where the request has historically come with national attention.
The timeline, as it stands.
Compliance is 20 July 2028. Brands buying nut butter as an ingredient are already demanding lot-linked data from processors, because their own FTL exposure depends on it.
Three moves that de-risk the deadline.
Lock supplier lot data at receipt
Every inbound raw-nut lot captured electronically with its KDEs — the foundation the grind records build on.
Treat each batch as a genealogy
Batch records linking input lots to output lots, captured at the line — this is what turns a national recall into a targeted one.
Map your fan-out
Know which customers took which lots within an hour. Your customers' recalls start with your shipping records.
The batch genealogy, written at the line.
Aeroz binds lot identity to totes, cases and pallets with chip carriers, writing receipts, transformations and shipments as EPCIS 2.0 events. When a lot goes bad, the system answers the two questions that matter — what went into it, and where did it go — in minutes, with a log a regulator can audit.
FSMA 204 for nut butters, answered.
Are nut butters really on the Food Traceability List?
Yes — nut butters are an FTL category, covering the processors who make them and the supply chain that handles them.
Does coverage extend to products containing nut butter?
The FTL entry covers the nut butter itself; finished products containing it as an ingredient are generally outside the FTL — but your customers still need your lot data when their product is implicated, which is why buyers demand it contractually.
What is the hardest record to keep?
The transformation genealogy — which raw-nut lots went into which finished batches. Kept at the line it is trivial; reconstructed after an event it is guesswork under pressure.
When is compliance required?
20 July 2028 under the FDA's extension, with commercial pressure from ingredient buyers arriving well ahead of it.
From the Aeroz blog
- 19 Million Eggs, One Carton Code: The 2026 Shell Egg Recall
- The Fallacy of the Batch Perimeter: Why Modern Supply Chains Require Item-Level Serialization
More answers: FSMA 204 questions in the compliance FAQ
Know exactly where you stand — in 14 days.
A fixed-fee Aeroz audit maps your products against FSMA 204 requirements for nut butters and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.