Food traceability in the US, Who is impacted?

April 16, 2024
Gael Lambert

In November 2022, a new regulation about Food Traceability with the catchy name of FSMA 204 was signed into law. Although the food industry was granted a grace period until Jan. 2026 to comply, a lot of preparation needs to be done before that enforcement deadline for the industry to be ready. The face value of the regulation is pretty straightforward. In principle, it consists of"just" translating the paper trail of the food supply chain to an electronic format to enable faster reaction in case of a food-related incident. It make sense that identifying products related to a single point of origin should be done more quickly by computers rather than a human sifting through paper purchase orders, bills of lading and receipt statements. That transformation, however remains a big challenge for those concerned. 


The big question, however, is who is impacted? As one of many, varied participants in the American food industry, do you have to prepare for the transition ? If you're reading this, then it seems very likely you do. However the most important consideration is what food product you grow/manufacture/distribute; the FDA has issued a Food Traceability List (FTL) with the definitive answer.  


But before going into the details, there are 2 main categories of stakeholders directly impacted by FSMA 204: 

  1. Domestic stakeholders 
  2. Foreign importers to the US 

Add to that a number of exceptions to confirm the rule. For the domestic stakeholders the rule is pretty simple: If you are touching one of the products in the FTL, you're directly affected. Farmers, transporters, transformers, wholesalers and retailers all have to start digitizing their supply chain documentation. For the foreign importers to the US, the above guidance applies and additionally, you'll have to conform with the Foreign Supplier Verification Program. Finally, Farms with a low enough turnover over the past 3 years are eligible for an exemption as well as some food product specified by the FDA. The FDA maintains a convenient list to determine if you can benefit from an exemption: Exemption list. If you fall into either of these categories, or are unsure if the law applies to you, first order of business is to confirm whether or not you have to comply. Assuming you do, don’t wait and start planning.  


While expert systems exist to support the traceability requirements of FSMA, underlying business processes are also impacted. In order to give yourself, and your organization, the time to work through those changes, do not hesitate to start asking questions. We'd be delighted to have a conversation with you. Reach out to us at