EXCLUSIVE: Why Stakeholders Shouldn’t Be Complacent About FSMA 204
Delay doesn’t mean dawdle. That’s one way to think about the recent decision by the U.S. Food and Drug Administration (FDA) to bump the compliance date for the Food Traceability Rule, also known as FSMA 204, by 30 months.
When announcing the extended compliance date for the final rule on traceability, the FDA underscored that the move was intended to give organizations more time to ensure complete coordination across the supply chain. That rationale was echoed by other industry stakeholders, including FMI - The Food Industry Association, which welcomed the opportunity to navigate complexities and mine good data to ensure efficient implementation.
Other food safety experts agree that time over the next two years should be spent wisely, not just for FSMA 204 rule compliance, but for better traceability that benefits all stakeholders. Progressive Grocer recently sat down with Sally Robinson, VP of strategic initiatives at Upshop, and Derrek Hannum, chief customer officer at ReposiTrak. Upshop is an SaaS platform that, among other things, digitizes fresh operations, optimizes inventory and manages omnichannel orders for the entire store; ReposiTrak is a food traceability and regulatory compliance network that leverages an established inventory management and out-of-stock reduction SaaS platform.
“We were hoping there would be a delay because we knew how unprepared the industry was. We have a front row seat to that, and we also know how long it takes, because we have customers who are two and a half years into their traceability journey and still journeying,” Hannum said. “So, the industry needs every bit of the 30 months but they key is that the industry can’t take that time for granted.”
Robinson concurred. “There are still some subsets who haven’t actually started doing the work or really digging into it, so I think that just keeping the momentum will be important.”
Robinson and Hannum reiterated the importance of finding ways to best maintain records containing key data elements and unlocking the ability to track down to the lot level. “This is a massive effort to modernize the supply chain and I think what you see right now is that the large chains were moving faster than the FDA anyway and still are,” Hannum observed. “But there are some inherent challenges in certain parts of the industry that have less to do with cooperation levels and willingness and more to do with complexity and the challenge of a complex supply chain. Produce and seafood for example, are really complex supply chains.”
As for what suppliers and retailers should be doing with their extra time, Hannum and Robinson offered some advice. “Data integrity is the problem inside the problem. The industry has to create easy data sharing, and it has to be good data,” Hannum remarked. “We know this because we are actively doing traceability with suppliers, retailers and wholesalers today – we see the data and have a means to vet and validate it and help them remedy problems. There's a lot of work to be done and our advice would be to get started.”
Robinson emphasized that there is positive intent in the industry on working towards better traceability. “I think it’s really about that intensive data layer and accuracy. It’s about using this extension to really know that the data is clean,” she said, noting that clean data offers other benefits. “It's a huge opportunity to add value to your store.”
In the meantime, solution providers like Upshop and ReposiTrak, among many others, are working with their supplier and retail partners to meet them where they are in achieving compliance on the route to data-driven traceability.
One such partner is Capital City Fruit Co. “We’ve been proactively preparing for FSMA 204 by working directly with both our retail and foodservice partners to transmit the required traceability data. Our internal systems are already capable of meeting many of the FSMA data requirements, and we've successfully integrated with key customers ahead of schedule. The extended timeline now gives us a valuable opportunity to bring our entire grower network up to speed — ensuring a fully traceable supply chain from farm to fork,” James Barth, food and occupational safety specialist at that company, told PG. “We're using this time to refine data capture at the source and align all partners with a consistent, compliant process.”
Capital City Fruit has engaged ReposiTrak to help collect, score and share critical tracking data required by FSMA 204.
Barth agreed that industry players can take advantage of the delay to get their proverbial house in order. “Don’t wait. Even with the extra time, FSMA 204 compliance is a heavy lift — especially when onboarding growers and aligning with customer-specific requirements. Traceability isn’t just a software install: it’s a shift in mindset and process across your supply chain,” he declared.
