How Lineage is preparing for FSMA 204 food traceability requirements
Traceability isn’t just compliance—it’s confidence
August 11, 2026
The Food Safety Modernization Act (FSMA) was signed into law in 2011 to shift the focus of food safety in the U.S. from reacting to contamination to actively preventing it. A recent and significant piece of that shift is Rule 204, also known as the Food Traceability Rule.
This rule establishes additional recordkeeping requirements for certain foods on the FDA's Food Traceability List (FTL) as they move through the supply chain. The goal is simple: when foodborne illness strikes, we need to know exactly where the food came from and where it went—fast.
The FSMA 204 compliance timeline has shifted to July 20, 2028, but for many food companies, traceability expectations are already evolving. Major retailers have introduced their own data exchange and labeling requirements, making preparation an immediate priority for suppliers across the food chain.
whether you're preparing for FDA requirements or meeting retailer-specific expectations, one thing is clear: the time to prepare is now. And Lineage is ready to help.
A Rule Rooted in Safety
The goal of FSMA 204 is straightforward: make it easier to trace certain foods through the supply chain so we can act faster when there’s a risk to public health. If there's an outbreak or contamination event, traceability allows for quick identification and removal of affected products—reducing harm, maintaining trust and protecting the people we all serve.
Under the rule, companies that manufacture, process, pack or hold foods on the FDA’s Food Traceability List (FTL) must:
- Identify applicable Critical Tracking Events (CTEs) throughout their operations — including activities such as harvesting, cooling, initial packing, shipping, receiving and transformation
- Maintain required Key Data Elements (KDEs) associated with those events, such as Traceability Lot Codes (TLCs), product descriptions, quantities, dates, location information and reference document information
- Maintain traceability records in accordance with the rule's recordkeeping requirements
- Provide required traceability information to the FDA within specified timeframes when requested
The Food Traceability List includes foods such as:
- Shell eggs (from domesticated chickens)
- Leafy greens like romaine lettuce and spinach
- Finfish such as salmon, tuna and tilapia
- Crustaceans including shrimp, crab and lobster
- Fresh-cut fruits and vegetables
- Soft cheeses like brie and camembert
- Tomatoes (whole and fresh-cut)
It’s more than just a recordkeeping update, it’s a shift toward real-time food safety data flowing across the supply chain.
Key Data Elements Lineage supports during receiving and shipping
| # | Key Data Element | Receiving | Shipping |
|---|---|---|---|
| 1 | Traceability lot code for the food | ✓ | ✓ |
| 2 | Quantity | ✓ | ✓ |
| 3 | Unit of measure | ✓ | ✓ |
| 4 | Product description | ✓ | ✓ |
| 5 | Location description, previous source | ✓ | ✓ |
| 6 | Location description | Receiver | Shipper |
| 7 | Date | Date received | Date shipped |
| 8 | Location description for traceability lot code | ✓ | ✓ |
| 9 | Reference document type (e.g., Bill of Lading or Purchase Order) | ✓ | ✓ |
| 10 | Reference document number (document ID) | ✓ | ✓ |
What It Means for Our Customers
If your business manufactures, processes, packs or holds foods on the FDA's Food Traceability List, FSMA 204 may require you to maintain additional traceability information associated with specific Critical Tracking Events. As products move between supply chain partners, maintaining accurate data and connecting it to the appropriate food and traceability lot becomes increasingly important.
At Lineage, we're preparing our systems and operational processes to support customers as traceability requirements evolve. Our warehouse management systems already capture many of the data elements used during receiving, storage and shipping, while our teams continue to strengthen data exchange, labeling and reporting capabilities across the network.
That includes supporting electronic data exchange between customers and supply chain partners, GS1 pallet labeling and retailer-specific requirements, along with existing EDI integrations that help information move alongside product.
And we’re not just building tech. We’re building trust.
Inside Our Approach
Supporting food traceability isn't a one-team job. Lineage has brought together a dedicated cross-functional FSMA team spanning food safety, operations, technology and customer support. Together, these teams are evaluating how data moves through our systems and facilities and how we can support customers as FDA and retailer expectations evolve.
“We’re looking at FSMA not just as a rule to follow, but as a way to build better systems for our customers,” said Dr. Stephen Neel, VP of Global Food Optimization at Lineage. “The more precise our traceability, the more resilient the food chain becomes.”
From internal audits to tech enhancements, our teams are laying the groundwork now to help make traceability processes easier to manage as requirements evolve.
Don’t Wait for 2028
Even though the FDA announced its intentions to extend the official deadline, many companies—especially those supplying to large retailers—are already being asked to meet FSMA-level traceability standards. That means the countdown has effectively started.
Here’s what you can do now:
- Evaluate your data flow. Understand how product and traceability information moves between your systems and supply chain partners.
- Define data exchange requirements. Determine which KDEs need to be shared, who provides them and how that information will be exchanged.
- Prepare warehouse processes. Account for traceability requirements across receiving, storage, inventory management and shipping.
- Align labeling requirements. Identify applicable GS1, pallet identification and retailer-specific labeling expectations.
- Test before deadlines. Test data, labeling and operational processes early enough to identify and address gaps.
Partnering Toward a Safer Future
Food traceability is a shared responsibility. Manufacturers, processors, warehouses, transportation providers and retailers each play a role in maintaining and exchanging information as products move through the supply chain.
Lineage's role is to support that process within our operations, helping customers capture, maintain and exchange traceability information as food moves through our network. By preparing our systems, teams and processes now, we're helping build a cold chain that's ready for evolving FDA and retailer expectations.
Let’s get ready for what’s next—together. Contact your Lineage rep today for more information.
Legal Disclaimer
We have prepared this material solely for informational purposes only, and you cannot definitively rely upon it. You are ultimately responsible for understanding, implementing, and complying with all applicable rules, regulations and guidance contained in and promulgated and issued under the Federal Food Safety Modernization Act (Pub. L. 111-353), including the FDA final rule entitled, “Requirements for Additional Traceability Records for Certain Foods” (Food Traceability Rule) (21 CFR part 1, subpart S (§§ 1.1300-1.1465)). Without limiting the foregoing, you remain responsible for the accuracy and completeness of information provided in support of your traceability obligations required under the Food Traceability Rule. This material may contain links to other websites or content belonging to or originating from third parties. Such external links are not investigated, monitored, or checked for accuracy, security, reliability, availability, or completeness by us. We do not warrant, endorse, guarantee, or assume responsibility for the accuracy or reliability of any information offered by third-party websites linked through this material. This material does not constitute an offer of any kind, nor bind either party to make or accept an offer.
