Retailers Face Tight Deadline to Meet New Food Traceability Standards
With less than a year to prepare, retailers are grappling with significant financial, operational, and legal challenges as they race to comply with new food traceability requirements set to take effect in early 2026. Section 204 of the Food Safety Modernization Act (FSMA), which mandates enhanced supply chain transparency, will require grocers to implement systems capable of quickly identifying and removing potentially contaminated foods. Failure to comply could result in serious legal repercussions.
Derek Hannum, Chief Customer Officer at ReposiTrak, emphasized the urgency during a November webinar hosted by the National Grocers Association (NGA). “Retailers must fully understand these requirements, as they share liability under the new rule,” he warned. As the January 20, 2026, deadline looms, here’s what grocers need to know to ensure compliance.
Understanding FSMA 204: Key Requirements for Grocers
FSMA 204 focuses on improving traceability for specific high-risk foods listed on the Food Traceability List (FTL), including soft cheeses, sprouts, tomatoes, crustaceans, and mollusks. Manufacturers, processors, packers, and distributors of these items must maintain detailed records containing Key Data Elements (KDEs) and be prepared to provide this information to the Food and Drug Administration (FDA) within 24 hours of a request. These records must be preserved for two years, tracking products as they move from suppliers to distribution centers, stores, and restaurants.
While some KDEs, such as traceability lot codes and product descriptions, can be printed on labels, others, like the date of receipt, cannot. This creates additional complexity for retailers, particularly those with central kitchens or deli operations that produce food in one location for distribution to multiple stores. In such cases, retailers must generate new traceability lot codes for transformed food items, adding another layer of data management.
Hannum stressed that if suppliers lack the capability to transmit lot codes and related data electronically, grocers and wholesalers will need to manually collect this information. He advised retailers to begin reviewing case labels and communicating lot code requirements to suppliers immediately.
A Three-Phase Approach to Traceability Implementation
To meet the new standards, Hannum recommended that retailers and wholesalers approach traceability implementation in three distinct phases:
- Supplier Onboarding: Establishing systems to enable seamless data sharing with suppliers.
- Distribution Center and Warehouse Traceability: Ensuring traceability systems are operational at these critical nodes in the supply chain.
- Store-Level Traceability: Implementing systems to track products at the final point of sale.
Traceability as a Competitive Advantage
While FSMA 204 sets the baseline for traceability, industry leaders like Kroger, Albertsons, and Walmart are already going beyond regulatory requirements, leveraging traceability as a competitive differentiator. Randy Fields, Chairman and CEO of ReposiTrak, noted that these retailers have implemented more robust traceability programs than the FDA mandates, with stricter timelines and broader product coverage.
For example, Kroger has extended its traceability requirements to all food products entering its facilities, not just those on the FTL. The grocer’s June 30, 2025, deadline is six months ahead of the FSMA’s. Catherine Cosby, Kroger’s Director of Food Safety and Regulatory Compliance, explained the rationale behind this proactive approach: “We don’t want to reconfigure systems if the FTL changes. This is both the right thing to do and the most efficient way to manage an evolving landscape.”
Cosby also highlighted the role of consumer expectations in driving these efforts. “Food safety is something consumers expect. They demand transparency about where their products come from,” she said during an appearance on Trustwell’s Food Tech Talk podcast.
Overcoming Challenges in the Supply Chain
Despite the progress, significant hurdles remain. Hannum pointed out that suppliers vary widely in their technical capabilities, complicating efforts to standardize traceability data. To address this, ReposiTrak recently partnered with store operations firm Upshop to improve grocers’ access to supply chain data.
Kroger, meanwhile, is developing a centralized system to consolidate supplier information and traceability data. According to its 2023 ESG report, the grocer completed initial systems design work in mid-2023 to enable product and data mapping across the supply chain. Cosby emphasized the importance of aligning tech teams with traceability requirements as part of the company’s broader evaluation of legacy systems.
The Road Ahead
As the 2026 deadline approaches, retailers must act swiftly to navigate the complexities of FSMA 204. While the regulatory requirements present significant challenges, they also offer an opportunity for grocers to enhance supply chain transparency, build consumer trust, and gain a competitive edge. Those who fail to adapt risk not only legal consequences but also falling behind in an industry where traceability is increasingly seen as a mark of excellence.
