Food traceability requirements that will go into effect in January 2026 are creating a significant shift in how the grocery industry operates. Retailers are now facing an urgent deadline to get their supply chains fully prepared to meet these new regulations. These requirements, under Section 204 of the Food Safety Modernization Act (FSMA), aim to enhance food safety by improving traceability and enabling faster identification and removal of potentially contaminated foods from the supply chain.
The new traceability rules apply to specific high-risk foods listed on the Food Traceability List (FTL), such as soft cheeses, tomatoes, sprouts, crustaceans, and mollusks. Businesses involved in manufacturing, processing, packing, or holding these foods must maintain records containing Key Data Elements (KDEs). These records must be made available to the FDA within 24 hours upon request and retained for at least two years. The required information includes traceability lot codes, product descriptions, and details about when the food was received, which must be collected at various points in the supply chain, from suppliers to distribution centers to retail locations.
Retailers with central kitchens or those who produce deli foods at one location for multiple stores will face additional challenges. For example, they will need to generate new traceability lot codes for transformed food products, adding an extra layer of complexity to their data tracking and record-keeping processes. In many cases, suppliers may not be able to provide the required lot codes and related data in a readily accessible format. This means grocers and wholesalers may need to develop manual systems to collect the missing information.
Implementing these new traceability measures will require grocers to adapt their operations in three key phases. The first phase involves onboarding suppliers to ensure that they can share the necessary traceability data. The second phase requires integrating this data within distribution centers and warehouses, ensuring that products are properly tracked at all stages of the supply chain. Finally, the third phase focuses on ensuring traceability at the store level, where the products reach consumers.
Larger retailers, such as Kroger, Albertsons, and Walmart, are already setting the bar higher for the industry by implementing traceability programs that go beyond the FDA’s requirements. These retailers have recognized the competitive advantage that robust traceability systems can offer, in addition to meeting the regulatory standards. For instance, Kroger has already established its own policy that covers all food products entering its facilities, not just the items specified by FSMA. This proactive approach is aimed at future-proofing their operations and minimizing the need for last-minute adjustments when regulations change or new products are added to the traceability list.
Customer expectations are also driving grocers to invest in traceability. Shoppers increasingly want transparency in understanding where their food comes from and how it is handled throughout the supply chain. The traceability system allows retailers to offer more transparency to consumers, helping them make informed decisions about the food they purchase and ensuring that retailers can quickly respond in case of food safety issues..
In conclusion, while the new food traceability requirements present challenges, they also offer significant opportunities for grocers to enhance their operations and meet customer demands for greater transparency. With less than a year before the regulations take effect, retailers must act quickly to ensure their supply chains are prepared. By investing in technology, working closely with suppliers, and staying ahead of regulatory changes, grocers can navigate the complexities of the new traceability rules and create a more efficient, transparent, and safer food system.