Mango Industry Faces 2028 Deadline for FDA Traceability Compliance

By Sana Tlemceni, Staff Writer

All businesses handling mangoes for U.S. consumption, from small growers to large importers, must comply with the U.S. Food and Drug Administration’s (FDA) Final Traceability Rule by July 20, 2028, the National Mango Board (NMB) has warned. The mandate applies equally to domestic and international supply chain actors, regardless of company size.

The reminder came during a recent NMB webinar, “The ABCs of the Food Traceability Final Rule,” held on September 24 and led by food safety specialist Sergio Nieto Montenegro. The session outlined the far-reaching implications of the regulation, part of the Food Safety Modernization Act (FSMA), which aims to strengthen food safety through improved tracking of products on the FDA’s Food Traceability List (FTL)—a list that includes mangoes.

What the Rule Requires

At its core, the traceability rule demands detailed recordkeeping across the entire mango supply chain. Every business involved in harvesting, packing, shipping, processing, or importing must document Critical Tracking Events (CTEs) and associated Key Data Elements (KDEs).

• CTEs are points in the supply chain where traceability is essential, such as harvesting, initial packing, shipping, receiving, and processing.
• KDEs include specific information such as product description, lot identification, origin and destination, dates, and reference documents.

A unique Traceability Lot Code (TLC) must be assigned either at initial packing or during food processing. That code will follow the mangoes through the entire supply chain.

“The rule states that only during initial packing or during the processing of your food, you will need to assign a TLC,” Nieto Montenegro explained. “And that TLC will be associated with the produce throughout the whole supply chain.”

Traceability Starts in the Orchard

The requirements begin at harvest. For growers, KDEs include product description (such as Ataulfo or Tommy Atkins mangoes), harvest quantity, orchard location, date of harvest, receiving facility, and transport documents.

At the packing stage, businesses must record orchard descriptions, reception and packing dates, product quantities, TLCs, facility addresses, and shipment destinations.

Once mangoes are shipped, records must include TLCs, origin and destination addresses, product descriptions, and shipping dates.

“At shipping, I’ll have my traceability lot code, quantity of product, description of the product, and the description of the location that will receive the product,” Nieto Montenegro said.

Building on Existing Systems

Industry participants were advised not to overcomplicate compliance. Instead, they should adapt current practices to fill any gaps.

“What I would recommend at the onset of this process is to see what you have already,” Nieto Montenegro noted. “After that, see what’s missing in your system, and if something is missing, add to it so you don’t go into any redundancy.”

The FDA allows businesses flexibility in how they keep records. Paper documentation is permitted, but electronic formats such as spreadsheets are encouraged. Importantly, in the event of a food safety crisis, companies may need to provide sortable records within 24 hours.

“The rule requires you to include a description of the procedures you use to maintain the records required for compliance, including the format of those records and the location where they will be stored,” Nieto Montenegro said.

Additionally, every operation must appoint a traceability contact person and provide a map of farm locations, complete with field names and GPS coordinates.

One Deadline for All

Unlike other FSMA rules, which stagger compliance deadlines by company size, the Final Traceability Rule sets a single compliance date: July 20, 2028.

“It will be a single date for everyone, regardless of the size of the company,” Nieto Montenegro emphasized.

The NMB has pledged to support stakeholders in the transition. “At the National Mango Board, we have plenty of tools at your service to help you create a plan in compliance with this rule,” he added.

Why It Matters: Protecting Public Health

The FDA’s ultimate objective is to strengthen the U.S. food safety system by enabling rapid responses during outbreaks. With robust traceability, authorities can quickly identify contaminated products, narrow recalls, and protect consumers.

“If I have a really solid traceability system, I know exactly the product that caused the problem, I can recall it and therefore protect public health,” Nieto Montenegro concluded.

Bottom line: For the mango industry, the countdown to compliance has begun. Whether a grower, packer, or importer, every business touching mangoes bound for U.S. consumers has fewer than five years to put a compliant traceability plan in place.