How to Get Ahead of FSMA 204 Traceability Requirements Before 2026
Section 204 of the Food Safety Modernization Act sets new standards for traceability in the food supply chain. It went into effect in 2023, but the U.S. Food & Drug Administration extended the compliance deadline, so food companies have to comply with the new requirements by January 20, 2026. Section 204 is one of the biggest updates to food-safety guidelines in the last 10 years, so FSMA 204 compliance is a hot topic in the CPG industry.
Any business that packs, processes, manufactures, or stores foods on the FDA Food Traceability List must comply with Section 204, regardless of its size. This means up-and-coming CPG brands have to comply just like established corporations do, assuming their products are on the Food Traceability List.
I've been mentoring emerging CPG brands for years, so I know that increased compliance requirements can feel burdensome, especially to brand-new business owners. However, the Section 204 compliance deadline gives you a valuable opportunity to improve data hygiene and supply-chain visibility within your business.
Instead of viewing the FDA food traceability rule as a burden, use it as a chance to implement systems and process changes that can make your CPG brand even more successful.
What FSMA 204 Requires (and Why it Matters)
FSMA 204 aims to enhance safety by making it easier to trace high-risk foods. The FDA Food Traceability List covers 19 food categories that have been linked to foodborne illness outbreaks, including soft cheeses, ready-to-eat deli salads, sprouts, and fresh melons. You're responsible for FSMA 204 compliance if your business produces, holds, packs, or processes any foods on the FTL.
In an effort to improve food safety compliance in 2026 and beyond, the FDA requires the following:
Lot-level identification
Visibility across critical tracking events
Traceability plans
Businesses subject to FSMA 204 also have to provide records required under the rule, including an electronic sortable spreadsheet with traceability data, to the FDA within 24 hours of receiving a request for the information. In simple terms, you have to trace food from production to sale, track specific key data points (key data elements), and maintain your records in a structured, retrievable format.
In addition to traceability lot codes, key data elements include:
Where the food was grown, packed, processed, shipped, harvested, or received
The amount of food involved in the event, including units of measure (e.g., 1,000 pounds of watermelon)
Bills of lading, purchasing orders, and other relevant reference documents
Dates associated with each Critical Tracking Event (e.g., date of harvest or date of shipment)
Point of contact for someone who can answer questions about the affected food and related records
Traceability doesn't just protect consumers from foodborne illnesses. It can also preserve your brand's reputation. FSMA 204 compliance shows consumers they can trust your company to do the right thing. It also enhances your credibility with prospective investors, suppliers, and employees.
Traceability Lot Codes: What to Change in Your Workflow
Lot code traceability helps you identify specific product lots, making it easier to comply with the FSMA 204 requirements. A lot code is a unique identifier, usually an alphanumeric code, assigned when the food is packed, received by the first land-based receiver (for food transferred from a fishing vessel), or transformed. The traceability code remains the same unless the food is transformed at some point in the supply chain.
Before you get too deep into the FSMA 204 recordkeeping requirements, you have a chance to upgrade your operations to account for the new lot traceability rules. You don't need an expensive tool to create your code system, although it's helpful if you already have inventory software or an enterprise resource planning package. If you're just starting out, you can create a simple Excel spreadsheet, as consistency and retrievability are more important than technical sophistication.
Creating Your Own Lot Code System
First, check the FTL to determine if your products are on the list. If they are, you have to create a lot code system that identifies production dates, batches, and ingredients. Here's an example:
LOT-20251001-ALBUT-02
This code identifies the production date (October 1, 2025), the batch number (02), and the ingredient of concern (almond butter). Lot codes need to be captured at the receiving, transformation, and shipping stages.
Once you finalize your preferred format, record key data elements for each CTE:
Supplier name, production facility name, or customer receiving the shipment
Date and time of the event
Product name and lot code
Quantity, weight, or item count
Facility or location
Even if your business is just a few months old, it helps to get into the habit of doing this now rather than waiting until January 20, 2026. By then, you might have more SKUS to manage, introducing complexity into your CPG regulatory planning.
Upgrading Recordkeeping for FSMA Compliance
Remember, you have to give the FDA relevant records within 24 hours of receiving a request. Paper records piled on your desk aren't going to cut it. You need a structured, digital recordkeeping system to help you meet the FSMA 204 requirements without stress.
Basic traceability records are helpful, but they're not necessarily compliant. A compliant record contains every piece of data the FDA requires to track products associated with foodborne illnesses. Be sure to capture data related to lot traceability codes, CTEs, and key data elements. When the compliance deadline hits, you'll be glad you got an early start.
You can start a digital traceability log with any of the following tools:
Inventory management systems
ERP integration
Airtable
Review your internal processes regularly to make sure team members don't skip important steps. You can align your recordkeeping system with FDA expectations by bookmarking the Section 204 final rule and reviewing it regularly. The FDA also has several resources related to key data elements, lot traceability codes, and CTEs.
What to Tackle in 2025 to Avoid a 2026 Fire Drill
With the FSMA 204 deadline approaching on January 20, 2026, now is the time to start transforming your business processes. At BBG, we have extensive experience helping emerging CPG brands meet their reporting requirements, so don't hesitate to contact us if you need compliance services to help you prepare.
In the meantime, here's a roadmap you can follow to ensure you're in compliance before the 2026 deadline.
1. Audit Current Traceability Practices
Before doing anything else, audit your current traceability practices to determine what changes to make. Think about which key data elements you're tracking, how you create and assign lot codes, and who's responsible for each aspect of these processes. A thorough audit can help you identify gaps and make a plan for addressing them.
2. Upgrade Lot Code Processes
Next, upgrade your lot code processes according to the tips I already provided. You can't train team members or create new records until you complete your new coding system, so make this a priority.
3. Provide Training
Don't wait until January 19 to start training employees on new compliance processes. Team members need time to learn your new coding system, ask questions, and practice the recordkeeping requirements. Before the training session, create some sample lot codes and allow employees to practice recording the data associated with each one. If you implemented a new software system to help with recordkeeping, give team members plenty of time to test its features.
4. Digitize Your Records
As I mentioned earlier, you don't need a complex tracking system to meet your FSMA 204 requirements. A simple spreadsheet can help you track lot codes, CTEs, and key data elements. If you have multiple SKUs, however, consider using Airtable or another tool to create digital records. Your IT team will need time to build a new recordkeeping system, so don't wait until the last minute to start the digitization process.
5. Confirm Supplier Compliance
Suppliers don't just provide raw materials; they also help your CPG brand remain in compliance with FDA rules. Before the FSMA 204 deadline hits, contact your suppliers to determine how they share lot information and track key data elements.
If necessary, request documentation to support each supplier's claims. Think packing slips, lot codes, and invoices. Update your standard operating procedures to ensure vendors understand what information they need to give your company.
Don't Wait for the Deadline to Hit
FSMA 204 is coming, but starting early can help you save time, reduce risk, and manage compliance-related stress. BBG provides tailored support designed to fit your company's size and current growth rate. Contact us today for expert assistance with traceability planning, FSMA compliance, or system implementation.
