Farmsoft USA
FSMA 204 food traceability for fresh produce
The FDA Food Traceability Rule requires firms that grow, pack, hold or ship foods on the Food Traceability List to keep key data elements for each critical tracking event and hand FDA a sortable spreadsheet within 24 hours. Producepak records them as the work is done.
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24 h FDA traceability spreadsheet from one search
Where the rule stands (October 2026)
- Final rule published November 2022; original compliance date 20 January 2026.
- March 2025: FDA announced a 30-month extension to 20 July 2028 (proposed rule 7 August 2025).
- November 2025: Congress barred FDA from using funds to enforce the rule before 20 July 2028 (Sec. 780, Public Law 119-37).
- Retail buyers are already asking suppliers for lot-level traceability data now.
Produce on the Food Traceability List
- Cucumbers, herbs, leafy greens, melons, peppers, sprouts, tomatoes and tropical tree fruits (fresh)
- Fresh-cut fruits, fresh-cut leafy greens and other fresh-cut vegetables
- Some exclusions apply, e.g. whole head cabbage under leafy greens
Critical tracking events and what Producepak records
| Critical tracking event | Who | Recorded in Producepak |
|---|---|---|
| Harvesting | Farm | Field/block, harvest date, commodity, quantity, farm map location |
| Cooling (before initial packing) | Farm or cooler | Cooling location and date, linked to the harvest lot |
| Initial packing of a raw agricultural commodity | Packer | Traceability lot code assigned at packing, packing location, source harvest lots |
| Shipping | Every shipper | Lot code, quantity, ship-to, ship date, TLC source; on the BOL and ASN |
| Receiving | Every receiver | Lot code received, quantity, ship-from, receive date; scanned at the dock |
| Transformation (e.g. fresh-cut, repack) | Processor / repacker | New lot code linked to every input lot |
Traceability plan in one place
- Procedures for keeping the records (format and location)
- How Food Traceability List items are identified
- How traceability lot codes are assigned
- Point of contact
- Farm map with field coordinates (farms growing FTL foods)
The 24-hour spreadsheet
When FDA asks during an outbreak or recall, the rule requires an electronic sortable spreadsheet within 24 hours. In Producepak a forward or backward trace on a lot or date range exports that spreadsheet in seconds, and the same search runs a mock recall for audits.
Questions
Do we have to comply now?
FDA cannot use appropriated funds to enforce the rule before 20 July 2028. The rule itself is in force and many retailers require the same data from suppliers today, so setting it up early avoids a rush.
Is a farm map really required?
For farms that grow FTL foods (other than eggs), the traceability plan must include a farm map with each field or growing area and its geographic coordinates.
Who assigns the traceability lot code?
The initial packer of a raw agricultural commodity, the first land-based receiver of seafood, or whoever transforms the food. Shippers and receivers pass the code on and do not create a new one.
Sources and further reading
- fda.gov – FSMA final rule on requirements for additional traceability records
- fda.gov – Food Traceability List
- Federal Register, 7 Aug 2025 – proposed compliance date extension
- foodsafetynews.com – the traceability rule and the 2028 enforcement date (Oct 2026)
- producepak.com – Producepak Fresh Produce App specifications (PDF)
See Producepak running on your product
Watch the short video, then book a live demonstration with a fresh produce consultant who knows US packhouses, PTI labels and FSMA 204.