Food traceability is no longer driven solely by regulation— it is now an operational standard set by industry leaders. While the FDA’s Food Safety Modernization Act Section 204 (FSMA 204) mandates traceability for certain high-risk foods, major retailers, wholesalers, foodservice operators, and quick-service restaurants (QSRs) are implementing broader and more demanding expectations.

These organizations now require:

  • Traceability for all food items, not just those listed on the FDA’s Food Traceability List (FTL)
  • Additional data elements for every shipment
  • Accelerated implementation timelines, often ahead of federal deadlines

This shift is reshaping supply chain practices and placing increased pressure on suppliers and trading partners to modernize their data exchange capabilities.

FSMA 204: Regulatory Overview

FSMA 204 requires entities that manufacture, process, pack, or hold foods on the FTL to:

  • Capture and maintain Key Data Elements (KDEs) for each Critical Tracking Event (CTE)—including shipping, receiving, and transformation
  • Exchange KDEs with trading partners to maintain traceability continuity
  • Provide traceability records to the FDA within 24 hours upon request, in a sortable electronic format

Affected businesses include food retailers, restaurants, foodservice distributors, and suppliers.

ReposiTrak Traceability Network® is Scalable, Practical, and Error-Resistant

The ReposiTrak Traceability Network® is the world’s largest traceability network, supporting over:

  • 12,000 retail stores
  • 8,000 suppliers
  • 36 distribution centers

It accepts supplier data in any format—via manual entry, automated feeds, or uploads from existing systems such as WMS or accounting platforms. Every file undergoes a 500+ point error detection process to ensure accuracy before reaching trading partners.

Key advantages include:

  • No changes to existing processes, hardware, software, labeling, or scanning
  • Electronic transmission of required data, including elements not available at the time of labeling
  • Data-agnostic ingestion, can extract and create the required Key Data Element (KDE) records using shipping and receiving documents in ANY format.

Labels Alone Are Not Sufficient for Compliance

While some traceability data can be printed on product labels, not all required information is available at the time of labeling. For example, shipment dates and receiving details are often finalized after labels are applied. To meet FSMA 204 and industry requirements, certain Key Data Elements (KDEs) must be transmitted electronically with every shipment. Relying solely on physical labels leaves critical gaps in traceability requirements.

Operational Value Beyond Compliance

While FSMA 204 sets the baseline, traceability delivers broader benefits. A robust traceability system helps mitigate recall risk, strengthens food safety practices, and improves supply chain transparency.

ReposiTrak enables organizations to meet regulatory and industry expectations with minimal disruption—and positions them for a bright future in food safety.

Click the Learn More links below to learn about traceability for Retailers and Wholesalers or for Suppliers. If you’d like a member of the ReposiTrak team to contact you about traceability, fill out the form below.