Are ricotta, feta or cream cheese in your recipes or on your shelves? These and the many, many more cheeses listed on FDA’s Food Traceability List (FTL) are now subject to more food traceability requirements under Section 204(d) of the FDA Food Safety Modernization Act (FSMA 204).
Food traceability is essential for enabling faster identification and rapid removal of potentially contaminated foods from the market. This article explores what FSMA 204 specifically means for soft cheese suppliers, including some of the essential steps to ready supply chains for January 20, 2026, the compliance deadline for all persons subject to FSMA 204.
What FSMA 204 Means for Soft Cheese Suppliers
Under FSMA 204, any organization that manufactures, processes, packs, or holds foods included on the Food Traceability List (FTL) must adhere to additional traceability recordkeeping requirements. Specifically, organizations must maintain records containing Key Data Elements (KDEs) associated with specific Critical Tracking Events (CTEs).
While hard cheeses are not on the FTL, many soft cheeses are, including cottage cheese, cream cheese, mascarpone, ricotta, brie, feta, and many more.
If called upon, organizations must provide information relating to these soft cheeses to the FDA within 24 hours, or within some reasonable time to which the FDA has agreed.
Could your organization meet this requirement with its current recordkeeping and traceability initiatives? Would you be confident that your suppliers have sufficient mechanisms in place to furnish you with the required information in a timely fashion?
If not, you need to take full control of the situation well ahead of the FDA’s compliance deadline to afford complete peace of mind. The good news is implementing full-scale traceability now is not only easy, but is also an opportunity to gain unmatched visibility into your supply chain.
Essential Steps to Take to Ensure Compliance with FSMA 204
There are several steps companies that deal with soft cheeses can take to ensure FSMA 204 compliance.
1. Familiarize Yourself with FSMA 204
First and foremost, you need to familiarize yourself with FSMA 204 and, in particular, the Food Traceability List, which contains a breakdown of the soft cheeses that require additional traceability records.
2. Determine What You Need to Record
Refer to the FDA’s resource guide on CTEs and KDEs to determine what your organization needs to record. It’s worth noting that your organization could be considered a receiver, a transformer, and a shipper, which increases the number of KDEs you’ll need to capture. The FDA has provided this video specifically for the cheese supply chain.
If you need help with this step, you can schedule a Traceability Assessment with ReposiTrak and The Acheson Group (TAG) for just $500. Learn more and fill out the form HERE.
3. Evaluate Your Customers’ Requirements
As a cheese supplier, you may receive some food products on the FTL such as fresh herbs that require additional tracking. However, the majority of your FSMA 204 requirements might have to do with what traceability data your customers require and the format in which they need to receive it.
It’s important to analyze the requirements of your retail, wholesale and/or manufacturing customers including which data they will need and how they want you to send it. In addition, it’s especially important to fully understand the Critical Tracking Events (CTEs) that are part of your operation and which Key Data Elements (KDEs) are required for each.
4. Implement Tracing Solutions
Start vetting traceability solutions now to determine which have all the features your organization requires, while causing minimum disruption during implementation and requiring little in the way of change to be effective.
Here are some example questions to ask when comparing different food traceability solutions.
- Does the company have experience collecting shipment data and sharing it between trading partners?
- Can your solution automatically track KDEs for product shipments between two different companies or facilities?
- Can your solution format KDE data into a traceability record and automatically store it for a period of at least 24 months?
- Can your solution provide a searchable data base by KDE for all traceability records?
- Can your solution automatically identify errors and send alerts for error resolution?
How to Leverage ReposiTrak’s Solutions
For more than 20 years, ReposiTrak has been solving supply chain collaboration challenges. The ReposiTrak Traceability Network enables farm-to-table traceability and can help you achieve FSMA 204 compliance.
Our solution requires:
- No additional hardware or software
- No substantial changes to your operations
- No labels or standards
It is also guaranteed to be the lowest-cost solution for suppliers, distributors, and retailers alike.
Interested in learning more about how to start your food traceability journey? Check out our recent webinar – Starting Your New Food Traceability Journey – to discover how your company can start its journey towards compliance now.
Don’t bear the burden alone. Set up your traceability and compliance management system with ReposiTrak. Join Now.