The Food and Drug Administration (FDA) has implemented a new regulation called the Food Traceability Rule or FSMA 204. This rule aims to create a better food safety system by tracking high-risk ingredients through the supply chain. We explain the Food Traceability Rule’s key points and help you determine if your restaurant is required to comply.
What Does the 2026 Food Traceability Rule Entail?
The core of the Food Traceability Rule lies in recordkeeping. Restaurants that meet certain criteria will be required to maintain records for specific foods on the FDA’s “Food Traceability List” (FTL). This list includes items like fresh fruits and vegetables, eggs, nut butters and spreads, cheeses, and more.
Restaurant management must document the movement of FTL items through critical tracking events (CTEs) in the supply chain. CTEs are points where ownership of the food changes hands, such as receiving a delivery or shipping product to a distributor.
For each CTE, restaurants must capture specific data points called key data elements (KDEs). KDEs typically include information like the date the food was received or shipped, the name of the supplier or buyer, a product description including the lot number, and the quantity of food purchased.
When Is the Compliance Date?
The compliance date for the Food Traceability Rule is January 20, 2026. This provides restaurants with ample time to prepare and implement the necessary procedures. The FDA is also allowing a grace period wherein routine inspections will not start until 2027.
Which Restaurants Need to Comply With the Food Traceability Rule?
The specific requirements vary depending on a restaurant’s annual food sales.
- Restaurants exceeding $1 million in annual food sales: These establishments must maintain electronic, readily sortable records that the FDA can access upon request.
- Restaurants with annual food sales between $250,000 and $1 million: These restaurants are exempt from the electronic recordkeeping requirement. However, they still need to maintain paper or digital copies of relevant documents like invoices and receipts that demonstrate traceability.
- Restaurants with annual food sales under $250,000: These establishments are currently exempt from the Food Traceability Rule.
How to Prepare for 2026
Here are some steps restaurants can take to prepare for the Food Traceability Rule:
- Determine your compliance status: Review your annual food sales to confirm if you fall under the rule’s purview.
- Familiarize yourself with the FDA’s Food Traceability List (FTL): Obtain a copy of the FTL from the FDA website to understand which food items you need to track. The FDA acknowledges that the food supply chain is constantly evolving. The agency has committed to periodically reviewing the RRM-FT and the FTL. This ensures the list remains relevant and reflects the latest trends and risks in foodborne illnesses.
- Develop a traceability plan: Establish a system for recording the required KDEs for FTL items. This may involve modifying your receiving procedures, training staff, and potentially investing in recordkeeping software.
- Communicate with suppliers: Lastly, inform your suppliers about the Food Traceability Rule. Encourage them to provide the necessary information on invoices or packing slips to facilitate recordkeeping.
Why Do We Need the Food Traceability Rule?
The Food Traceability Rule was designed to enhance food safety by enabling faster and more targeted recalls in case of a contamination outbreak. Foodborne illnesses are a significant public health concern, causing millions of illnesses and even deaths each year in the US.
Ideally, this new rule will make it easier to trace back to the source of contamination, which is always a challenge, thereby reducing the number of consumers exposed to potentially harmful foods. Having a faster way to trace foodborne illness also reduces the economic impact of recalls by pinpointing the source of contamination more efficiently. The FDA also hopes to strengthen consumer confidence in the food supply chain once the new traceability rules are in place.
Traceability Is a Work in Progress
The FDA’s Food Traceability Rule represents a significant step towards a safer and more transparent food supply chain. Restaurants have time to prepare and we recommend familiarizing yourself with the rule and implementing a compliant recordkeeping system. By taking proactive measures, restaurants can ensure they comply with the regulations and contribute to a safer food experience for their customers.
