What the FSMA Food Traceability Rule Means for Foodservice Operators
The Food Safety Modernization Act (FSMA) Final Rule on Requirements for Additional Traceability Records for Certain Foods—commonly referred to as the Food Traceability Rule—marks a significant shift in food safety regulations. Designed to enhance the ability to track certain high-risk foods through the supply chain, it is a game-changer for foodservice operators.
With compliance deadlines approaching, foodservice businesses must understand how these changes affect their operations and what steps must be taken to comply.
What Is the FSMA Food Traceability Rule?
The FSMA Final Rule on Food Traceability, issued by the FDA, establishes new recordkeeping requirements for certain foods identified as “high-risk.” The rule is part of a broader effort to improve food safety by enabling faster identification and response to foodborne illness outbreaks.
At its core, the rule requires more detailed recordkeeping and traceability for foods on the FDA’s Food Traceability List (FTL), which includes items such as:
Fresh fruits and vegetables (e.g., leafy greens, tomatoes, cucumbers)
Cheeses (soft, semi-soft)
Shell eggs
Ready-to-eat deli salads
Certain seafood products
The rule applies to all entities handling these foods in the supply chain, from manufacturers and distributors to foodservice establishments.
Key Milestone and Compliance Dates
Understanding the timeline for compliance is critical for foodservice operators. Here are the key dates to keep in mind. The FDA officially published the Final Rule on Food Traceability–outlining new recordkeeping and compliance requirements—on November 21, 2022. It formally took effect–meaning businesses had to begin preparing for its implementation–on January 20, 2023. For foodservice operators now, January 20, 2026 is the most important date to know: that is the mandatory compliance date for all covered entities, including foodservice operators. By this date, businesses must:
Have traceability recordkeeping systems in place.
Ensure they can provide traceability records within 24 hours if requested by the FDA.
Train staff on new tracking and recordkeeping procedures.
The FDA is expected to release additional guidance and updates leading up to this deadline. Foodservice operators should stay informed about any clarifications or modifications.
What This Means for Foodservice Operators
Foodservice operators, including restaurants, cafeterias, caterers, and institutional food providers, must now adopt more rigorous tracking procedures for ingredients on the Food Traceability List. While the rule primarily affects suppliers and distributors, foodservice businesses that receive, prepare, or sell these products will also need to maintain traceability records and ensure compliance with new documentation requirements.
Key Requirements
Enhanced Recordkeeping for Traceable Foods
Operators must maintain specific records for foods on the FTL, including from where they were received and, in some cases, to where they were sent or used. These records must include lot codes and other identifiers.Tracking Key Data Elements (KDEs) for Critical Tracking Events (CTEs)
KDEs include information such as shipment dates, lot codes, product descriptions, and supplier details.
CTEs refer to events such as receiving, transforming (e.g., processing), and shipping food.
Even if foodservice businesses don’t ship products further downstream, they may still need to track and retain KDEs for received products.
Records Must Be Available Within 24 Hours
If requested by the FDA, businesses must be able to provide the required traceability records within 24 hours to support rapid response in the event of a foodborne illness outbreak.Digital Recordkeeping is Encouraged
While the rule does not mandate electronic recordkeeping, using a digital traceability system can significantly streamline compliance. Many foodservice operators are investing in cloud-based inventory and supplier management systems to ensure seamless data tracking.Training Staff on Compliance
Employees handling purchasing, receiving, and inventory management should be trained on the new requirements. They need to understand what information to capture, how to store records, and how to retrieve them if needed.
How To Prepare
To ensure compliance with the FSMA Food Traceability Rule, foodservice operators should take the following steps:
✅ Review Your Supply Chain
Identify which of your ingredients are on the FTL and ensure suppliers are also complying with the new requirements.
✅ Update Recordkeeping Processes
Ensure that you are capturing all required traceability data, including lot codes and supplier information, and that records are organized for quick retrieval.
✅ Leverage Technology
Consider investing in digital inventory management systems to simplify traceability tracking and compliance. These systems can automate recordkeeping and reduce the risk of errors.
✅ Train Your Team
Educate key staff members on the new rules and their role in maintaining accurate records. Conduct regular audits to ensure compliance.
✅ Stay Informed
Regulations evolve, and so staying up to date will help you remain compliant. Regularly check FDA updates, attend industry webinars, and work with suppliers who are knowledgeable about FSMA requirements.
Compliance Is Key
The FSMA Food Traceability Rule is a significant step toward a safer, more transparent food system. For foodservice operators, compliance might require some adjustments to existing processes, but proactive preparation will make the transition smoother. By implementing strong recordkeeping practices, leveraging technology, and training staff, operators can ensure they remain compliant while continuing to deliver safe, high-quality food to customers.
Want to Learn More?
For further details, visit the FDA’s official page on the FSMA Final Rule. Also, consider partnering with industry experts, compliance consultants, or food traceability technology providers to help navigate the new requirements.
By taking action now, foodservice operators can protect their businesses, ensure food safety, and stay ahead of regulatory changes.
